Remuneration Policy and Procedures | Purpose and Responsibilities | Mortgage Conduct of Business MCOB | Template for FCA Applications and Authorised Firms

Remuneration Policy

1) Purpose

The purpose of this policy is to provide the company intent and approach with regards remuneration and to ensure that we comply with the regulatory requirements as laid out by the FCA in section SYSC 19 of their handbook.

We maintain a clear and detailed records of all remuneration procedures and any associated documents, which includes (but is not limited to), performance appraisals, interviews, contractual agreements and remuneration structures.

We promote a fair and transparent remuneration system and are able to provide risk assessments for each remuneration area to show that any associated operational or external risk has been identified, considered and mitigated against where applicable.

2) Objectives

It is the company’s aim to ensure that: –

• Any remuneration benefits (health cover, pensions etc) have their own policies and have been put into place after careful risk assessments have been carried out
• We have a robust and clear remuneration structure in place which is available to all staff
• Staff are remunerated in accordance with the achievement of the objectives linked to their functions, independent of the performance of the business areas they control
• Remuneration and any associated benefits are adequate to ensure qualified and skilled staff are attracted to the relevant positions
• We identify any Code Staff and keep their details recorded for regulatory purposes
• Have measures in place to ensure that all Code Staff are made aware of the policies, procedures and regulations regarding remuneration and that they understand any implications of this status in relation to the requirements of the Code
• Have procedures in place to ensure effective risk management
• Have a robust Conflicts of Interest Policy, Procedures and employee guidance in relation to remuneration
• Consumers are always made aware if we are paid by commission and are advised of their right to ask for information on the commissions paid by different lenders. They are also provided with ways to access relevant market data to allow them to respond to such a request
• We comply with the Mortgage Credit Directive (MCD) and ensure that the remuneration of our advisers is not contingent on any of their sales targets

3) Reward Schemes

[Detail any bonus schemes or other reward schemes that you have in place to remunerate or incentivise Code Staff for performance]

• Add scheme here
• Add scheme here
• Add scheme here
• Add scheme here

4) Responsibilities

It is the responsibility of all managers to ensure that this policy is disseminated to and understood by all code staff and that the supplementing procedures and regulatory rules are made clear and accessible at all times.

Code staff are expected to comply with regulatory requirements in addition to the firm’s policy and procedures on remuneration and to understand the Remuneration Principles as defined in the FCA handbook.

7.19.1 INSERT: Remuneration Procedures         

[Insert your existing procedures for Remuneration & Benefits here, ensuring that they comply with the requirements under SYSC 19 as applicable to your firm.]