Description

A focused course, tailored for you

CRD Remuneration Governance for Global Banks

Build the MRT identification, variable pay architecture, and supervisory submission that withstands the ECB proportionality review.

The EBA proportionality review returns with open items on the MRT identification perimeter. Not on the total headcount, on the documented methodology for who qualifies and why. The question that keeps recurring is how to make that documentation defensible not just this cycle, but for new hires, restructures, and future supervisory cycles where the methodology is tested by someone who was not in the room when it was built.

$199 one-time

Tailored to your situation. Access within 24 hours. 30-day money-back.

Includes a hand-built implementation playbook delivered alongside course access, generated for your specific situation.

Why this course

For the Head of Governance and Compensation at a major bank, the remuneration governance cycle is simultaneously the most technically demanding and most board-visible work in the role. The MRT identification drives every downstream pay constraint, but the methodology for drawing the perimeter is rarely fully documented to ECB or ACPR standards. The variable pay architecture needs to be competitive enough to retain key talent while staying within CRD caps. The supervisory submission needs to anticipate every follow-up question before it is asked. Proxy advisors have their own framework, institutional shareholders have theirs, and the board has to sign off on a remuneration policy that serves all three audiences. Most of these challenges are solved one cycle at a time rather than built systematically into a repeatable governance framework.

What you walk away with

Document the MRT identification methodology to ECB and ACPR standards, with a defensible rationale for both inclusions and exclusions.
Build the remuneration committee governance calendar and charter that meets EBA Guidelines on Internal Governance.
Structure variable pay architecture within CRD caps, with the shareholder approval roadmap for the two-to-one route where needed.
Design the malus and clawback framework with documented trigger events and a governance process for enforcement across jurisdictions.
Prepare the SREP remuneration questionnaire and supervisory submission that closes the cycle without follow-up items.
Build the annual governance calendar that runs from MRT review through the AGM say-on-pay resolution with no governance gaps.

The 12 modules

Module 1. MRT Identification Methodology

Every remuneration governance failure starts with a perimeter that was never properly documented. This module builds the MRT identification methodology from the EBA quantitative criteria, including total remuneration thresholds and business unit attribution, through the qualitative criteria covering risk-taking authority, decision-making proximity, and management body access, to the documentation structure the ECB and ACPR expect. You leave with a written methodology that survives multi-year supervisory scrutiny without rebuild.

Module 2. Remuneration Committee Governance

The RemCo charter and governance calendar are the infrastructure everything else runs on. This module structures the committee mandate covering independence, quorum, and decision rights versus management authority, the annual cycle from MRT identification sign-off through policy approval and supervisory reporting, and the minute-taking discipline that creates an auditable trail for supervisory review. You produce a charter template and a twelve-month calendar with no gaps between the pay review cycle and board approval.

Module 3. Variable Pay Architecture under CRD

The one-to-one base-to-variable cap, the two-to-one shareholder approval route, and the identified staff tier structure define the framework. The implementation question is how to build pay packages that are both regulatory compliant and competitive with institutions in non-CRD jurisdictions. This module maps the CRD cap rules to your existing compensation structure, identifies which roles require shareholder approval, and builds the disclosure narrative for the general meeting resolution.

Module 4. Deferral Structures and Vesting Schedules

CRD minimum deferral requirements vary by identified staff category, and the rules on eligible instruments including shares, share-linked instruments, and Additional Tier 1 add complexity. This module builds the deferral matrix by staff category, models the vesting schedule options against retention objectives, and builds the governance documentation for the RemCo to approve each year. Cross-border complications when executives hold deferred awards across multiple legal entities are addressed in the harmonization workbook.

Module 5. Malus and Clawback Frameworks

The malus trigger list, the governance process for applying an adjustment, and the documentation trail for enforcement are three pieces that most remuneration frameworks have only partly assembled. This module defines trigger events covering conduct breach, financial restatement, regulatory censure, and personal culpability with governance thresholds for each, builds the RemCo decision-making process for initiating a review, and creates the legal and HR workflow that enforces adjustments consistently across jurisdictions.

Module 6. Cross-Jurisdictional Harmonization

A group remuneration policy that works across EU entities, UK branches, and US subsidiaries requires a mapping of where local law diverges from the CRD parent framework. This module inventories the major variance points including the DORA operational resilience linkage in the EU, the PRA Senior Managers Regime overlay in the UK, and Fed guidance on incentive compensation in the US, and builds the harmonization methodology that maintains group coherence without overriding local legal requirements.

Module 7. Pay Equity and Gender Pay Gap Reporting

The EU Pay Transparency Directive introduced reporting obligations and employee information rights that intersect directly with the remuneration governance framework. This module builds the internal pay analysis methodology covering job evaluation, like-for-like comparisons, and adjusted versus unadjusted gap calculations, the board narrative for the remuneration report, and the governance response process for identified gaps. Proxy advisor expectations on pay equity disclosure are mapped alongside the legal minimum requirements.

Module 8. Proxy Advisor Alignment

ISS and Glass Lewis have distinct evaluation methodologies for banking sector pay, and at a major EU institution the divergence between the two creates real complexity for RemCo. This module maps the key scoring criteria each proxy advisor applies to executive variable pay, pay ratio disclosure, and malus and clawback track record, and builds the remuneration report sections that address their primary concerns before the AGM season review cycle begins.

Module 9. Say-on-Pay Strategy

Managing the say-on-pay resolution requires a twelve-month strategy, not a two-week communication effort before the AGM. This module structures the institutional shareholder engagement calendar covering target audiences, pre-AGM outreach sequencing, and board director availability for direct dialogue, the response framework for adverse proxy advisor recommendations, and the post-AGM reporting to the RemCo on voting outcomes and engagement effectiveness. Includes the dissent threshold analysis that triggers a formal governance response.

Module 10. SREP Remuneration Assessment

The supervisory review and evaluation process has a specific remuneration component that most banks treat as a compliance exercise rather than a governance quality signal. This module works through the ECB and ACPR remuneration questionnaire structure, the evidence package the supervisor expects including methodology documents, RemCo minutes, policy approvals, and MRT identification rationale, and the response protocol for follow-up questions that arrive after submission. Closes with a self-assessment template for internal pre-submission review.

Module 11. Governance Documentation and Board Reporting

The remuneration policy document, the implementation report, the board-level summary in the AGM circular, and the supervisory package are four distinct outputs with four distinct audiences. This module builds each document structure from the audience's primary question, whether the board is asking about competitiveness and compliance, the supervisor is asking about methodology defensibility, or shareholders are asking about pay-for-performance alignment, and creates a drafting process that produces all four from a single source of truth.

Module 12. The Annual Cycle and Continuous Improvement

The full governance calendar runs from the January MRT identification review through the AGM say-on-pay resolution and back to Q4 performance assessment, RemCo approval, and SREP preparation. This module maps every handoff point, assigns governance accountability for each milestone, and builds the post-cycle retrospective process that captures supervisory feedback, shareholder commentary, and internal gaps for the following year. Leaves you with a governance operating model that runs without rebuilding from scratch each cycle.

How this addresses your situation

Specific modules that map to what you said you are dealing with.

An EBA proportionality review returned with open items on MRT identification methodology. Modules 1 and 2 resolve it and produce the document the supervisor needs to close the finding.

The RemCo governance calendar has gaps between the annual pay review cycle and the board approval dates. Module 2 restructures it with a twelve-month calendar that closes every gap.

The shareholder engagement strategy for say-on-pay needs to be built before proxy advisors circulate their recommendations. Modules 8 and 9 build it with twelve months of lead time.

The SREP remuneration submission is rebuilt from scratch each year with no repeatable template. Modules 10 and 11 create the template and the evidence structure that makes each cycle faster.

What you get with this course

Twelve written modules in the Art of Service learning environment.
MRT identification methodology template covering quantitative and qualitative criteria with documentation structure.
Remuneration committee charter template with full twelve-month governance calendar.
Variable pay architecture workbook with CRD cap analysis and deferral matrix by identified staff category.
SREP remuneration questionnaire preparation guide with evidence package checklist.
Proxy advisor alignment analysis framework structured for RemCo pre-season review.
Hand-built implementation playbook tailored to your governance perimeter, delivered alongside course access.

What you will have in hand by Day 1, Week 1, Month 1

Within 24 hours your account in the learning environment is provisioned and the tailored implementation playbook is delivered alongside it.

Before and after

Before

MRT identification rebuilt from scratch each year with no documented methodology, variable pay architecture patched to address supervisor feedback cycle by cycle, supervisory submission drafted without a repeatable template, proxy advisor alignment managed reactively in the weeks before the AGM.

After

Documented MRT methodology that runs consistently across supervisory cycles, structured variable pay framework within CRD constraints with a clear shareholder approval roadmap, supervisory submission built from a repeatable evidence template, RemCo governance calendar that runs the full year without gaps.

What happens if you do not address this

The next supervisory cycle returns with the same open items on MRT methodology. A new hire triggers identification criteria that were not cleanly documented when the perimeter was drawn. The RemCo chair asks why the governance calendar does not connect the pay review cycle to the board approval dates. A key hire rejects the offer because the deferral ratio is not competitive with institutions outside the CRD perimeter. Each of these is recoverable individually. Together they signal a governance framework built for the last cycle, not the current one.

Who it is for

This course is for the senior governance or compensation professional at a bank supervised under CRD, who owns the MRT identification process, the remuneration committee governance calendar, and the annual supervisory submission. Typically Head of Governance and Compensation, Head of Executive Remuneration, or Chief Governance Officer at a Group 1 or Group 2 institution. Has deep compensation expertise but needs a structured methodology for the supervisory-defensibility layer, not more general guidance on pay design principles.

Who this is NOT for. Not for HR generalists or compensation analysts working on salary bands and job grading. Not for banks outside the CRD and EBA supervisory perimeter. Not for governance professionals without direct accountability for the RemCo secretariat, the MRT identification sign-off, and the annual supervisory submission.

How it arrives

Text-based course in the Art of Service learning environment, plus downloadable templates and worked examples for every module, plus the hand-built implementation playbook delivered alongside course access.

Time investment. Twelve modules. Estimated eight to ten hours for the full course. Individual modules can be completed in forty to sixty minutes each.

Why $199 is the right number

Regulatory training at ECB or EBA events covers the framework but not the implementation methodology. Legal counsel advises on compliance but will not build your governance templates. Peer benchmarking with other RemCo secretariats gives you data but no structured approach to the supervisory-defensibility layer. This course builds the implementation layer that sits under all of those.

FAQ

Is this relevant to a bank supervised under ACPR rather than directly by the ECB?

Yes. The course follows EBA Guidelines on sound remuneration policies, which apply under CRD regardless of whether the supervising authority is the ECB directly or through a national competent authority. French-specific transposition details and ACPR supervisory expectations are addressed in the SREP preparation module.

Does this cover investment firm subsidiaries under IFR and IFD as well as the banking entities?

The core course addresses CRD remuneration governance. The variable pay and MRT identification modules include a cross-jurisdictional harmonization framework that covers IFR and IFD Investment Firm categories and the differences in identification criteria and pay caps compared to the CRD parent framework.

Will the implementation playbook be specific to our governance structure or generic?

The playbook is hand-built for the governance structure you describe when you enroll. It uses your RemCo charter structure, your entity perimeter, and your current MRT identification approach as the starting point, not a generic banking template.

30-day money-back guarantee. If after a week of working through the materials this is not what you needed, reply to the receipt email and a full refund is processed. No questions, no forms.

Within 24 hours your account in the learning environment is provisioned and the tailored implementation playbook is delivered alongside it.