European Banking Authority Publishes Guidelines for Data Collection on EEA Remuneration Practices

On July 27, 2012, the European Banking Authority (“EBA”) published two sets of guidelines which, when implemented by national competent authorities (“National Authorities”), will advise affected institutions how to submit data regarding high earners and remuneration benchmarking to their National Authorities as required by the amended EU Capital Requirements Directive (“CRD III”). The National Authorities must implement these rules by September 30, 2012. Affected institutions must then file the first reports by December 31, 2012, covering remuneration data for 2010 and 2011. Upon receipt of data from the National Authorities, in turn, the EBA will publicly disclose the data on an aggregate Member State by Member State basis. This public disclosure is likely to raise significant political discussion and media coverage throughout Europe.