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From the Opalesque team: According a report from the international law firm Schulte Roth & Zabel, the UK Financial Services Authority (FSA) published its delayed policy statement and final rules on its Remuneration Code on Dec. 17th, 2010 – following a consultation published in July. This consultation set out revisions to the Code, which previously only applied to large banks.

The final Code now shows that the FSA has introduced a ‘tiered’ proportionality test; that most UK-based hedge fund managers and UK affiliates of US-based hedge fund managers will not have to comply with the provisions of the Code that require the deferral of bonuses to Code Staff, and the payment of 50% of variable remunerations; that rules on guaranteed bonuses should now be applied to all employees and not just to Code Staff; and that even Tier 4 (the lowest tier) firms remain subject to complying with the Code and must maintain appropriate records.

UK-based hedge fund managers, as Tier 4 firms, must review their remuneration policies to ensure that they are consistent with the Code, although Disapplied Principles are permitted in some cases.

Over the course of the next two weeks, says the law firm, UK-based hedge fund managers should take the following steps:

- Identify which tier the firm will be in. - Analyse group structure and identify all EEA regulated entities and their branches and subsidiaries. - Establish which Principles the firm is able to di......................

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