MFA Submits Comment Letter to ESMA on MiFID Remuneration Guidelines

MFA submitted a comment letter to ESMA in response to ESMA’s consultation paper on remuneration guidelines under MiFID.  In the letter, MFA encouraged ESMA to make clear that the principle of proportionality applied to all of the guidelines and that proportionality included the right for Member State regulators to completely neutralize individual guidelines with respect to certain types of MiFID firms, similar to the approach taken regarding remuneration principles and guidelines under the Capital Requirements Directive.  MFA also encouraged ESMA to narrow the scope of relevant persons and the intended scope of remuneration policies to focus on areas most relevant to potential conflicts of interest in connection with remuneration policies.