Although such a period is longer than the minimum deferral period of three years targeted by  10  For evidence on remuneration in the financial sector, see Philippon T. and A. Reshef (2009), “Wages and Human Capital in the U.S. Financial Industry: 1909–2006”, NBER Working Paper No. 14644, January.
11  Note that the underlying logic of the European Commission approach is aligned with the FSB’s Implementation Standard 12, according to which “Existing contractual payments related to a termination of employment should be re-examined […]; prospectively, any such payments should be related to performance achieved over time and designed in a way that does not reward failure”.