There has been growing concern in recent months, that rewarding short-term revenue and profit targets through improper remuneration practices may have contributed to the credit crisis. On 18 March 2009, the Financial Services Authority (the “FSA”) published the consultation paper, “09/10 ? Reforming Remuneration Practices in Financial Services” (the “Consultation”).1 At the heart of the Consultation’s proposals, is the view that the FSA’s draft Code of Practice (the “Code”) published on 26 February 2009,2 should be incorporated into the FSA Handbook and applied to certain financial institutions, including large banks, building societies and broker dealers.

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