Pillar 3 Disclosure Requirements for Remuneration

SIFMA provides comments to the Basel Committee on Banking Supervision (BCBS) on proposed Pillar 3 disclosure requirements for remuneration.  SIFMA believes in the disclosure of compensation information to supervisors and public disclosure of certain qualitative information to the public to the extent that it enhances prudent risk management. SIFMA shares its concerns that mandatory public disclosure of quantitative data is a new regulatory approach that should not be undertaken lightly, particularly given the inherent privacy, confidentiality and competitive concerns.