For those who are directly affected by the Remuneration Code, today is a milestone. In their policy statement (PS 10/20), the FSA made clear that it expects firms that have not yet fully implemented the Code (especially Principles 1-6, 9, 10 and 11) to have in place by the end of January ‘a time specific plan’ for implementation. As firms have had so little time since the publication of the rules, it is well understood by FSA that implementation is unlikely to be complete and hence the deferred deadlines. However, the implementation plan is the quid pro quo for this deferral and is a mechanism for FSA to be able to see that the process has begun and the firm knows how it will bring into play the relevant parts of the Code. Nevertheless it is clear that many firms are still uncertain precisely how to proceed, looking in many cases for further guidance. If you want to discuss implementation plans, give us a call.