Last year(2010), Gordon Brown's phrase 'no payment for failure' seems to have latched on to the UK financial services regulator(FSA) and UK headquartered banks(Standard Chartered/HSBC etc). Read their Pillar III disclosures and this phrase jumps out at you. Considering all the public outcry over bankers getting fat bonuses despite their bank being bailed out, it only seems reasonable that bankers are not rewarded for failure(of their institution) at a group level, or even individually(if they do not meet their targets).
But from the public disclosures(in Pillar III), what I gather about the implementation is that
- Stringent performance targets will be set covering profit, risk, people etc. These targets will be mostly in number of shares/options.
- The performance bonus will be adjusted for 'risk'(any adjustment to be DOWNwards only)
- Even after that, the vesting of the options/shares will be subject to clawback, deferral and overall group criteria in terms of total shareholder return, economic profit etc.
- And finally, a significant number of people will be awarded Zero bonuses.
So those days of hitting a purple patch and then quitting the industry are gone. Even if a banker(trader/structurer/investment banker etc) is eligible for a $10MM bonus, chances are
- Immediate cash component will be capped at 10%(viz $1MM-for RBS it is 2000GBP!!!!)
- The rest will be paid out in terms of restricted shares-subject to market price risk and insolvency risk
- The bonus can be clawed back for N number of reasons-including quitting the organization etc
Given that top bankers are somewhat like top athletes(in terms of peak earning years), this does seem unfair to cap a lottery type payout. And then awarding zero bonuses for average performers is also hard to justify-if the base pay is not increased accordingly.
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