Dass nicht alles Gold ist an der laufenden bAV-Reform, ist...
Gabriel Bernardino in Frankfurt:
„We are ready to listen, discuss and evolve in our proposals.“
Auf der Euro Finance Week im vergangenen November erläuterte der EIOPA-Chef in zwei Reden seine Vorstellungen und die seiner Behörde betreffend das betriebliche Pensionswesen.
Ende Dezember 2014 hatte Leiter-bAV.de berichtet, dass die europäische Aufsichtsbehörde EIOPA im November und Dezember 2014 eine Aktivität an den Tag gelegt hat, die das übliche, an sich schon nicht zurückhaltende Maß weit übertrifft.
Einige der das betriebliche Pensionswesen betreffenden EIOPA-Vorstöße werden in diesen Tagen auf Leiter-bAV.de dokumentiert. Heute: Die Reden des EIOPA-Vorsitzenden Gabriel Bernardino auf den Pensionsveranstaltungen im Rahmen der Euro Finance Week im November 2014 in Frankfurt am Main.
Im folgenden unkommentiert wesentliche Auszüge aus Bernardinos Rede „Topical developments on pensions: an EIOPA perspective”, gehalten auf dem 9. European Pension Funds Congress am 18 November 2014 (Datei verlinkt hinter dem Bild):
Die übergeordneten Ziele der EIOPA im Zuge der Regulierung des Pensionswesens:
„This regulatory framework needs to deliver on three fundamental objectives: enhanced sustainability, strong governance and full transparency. These are the fundamental building blocks of EIOPA’s pensions’ vision.“
Zum Pensionswesen im Grundsätzlichen:
„In all our work we recognise that pensions are different from other areas.
Pensions are different because of their 'embeddedness' in social and labour law; because of their social objectives; because of their particular governance, involving employers and social partners; different because of their unique distribution of risks.
But, in spite of these differences, members and beneficiaries are citizens who deserve adequate protection, who have the right to know the sustainability of the promises that are made to them, who need to understand the risks that they are running, the costs that they are paying, who deserve that pension funds are properly governed and that pension schemes have a high degree of quality.
So pension funds need specific regulation that takes into account these differences and that’s what EIOPA has been advocating and practising.
– By developing an innovative 'Holistic Balance Sheet' approach that takes into consideration all benefit adjustment and security mechanisms, such as sponsor support and pension protection schemes, capturing the specificities of pension funds in the various member states;
– By recommending an upgrade in the governance of pension funds, reinforcing the importance of proper risk management and control functions, while applying due proportionality to avoid undue burden and costs to smaller schemes;
– By advocating the development of a Key Information Document that should provide standardised information on contributions, costs and charges, investment options and expected benefits.
But also recognising that 'too much' information kills information and that we should adopt a layering approach where members will receive simple and comparable information on the key elements and would have easy access if they wish to all the other more detailed material.“
Zur positiven Wirkung der Regulierung auf EbAV am Beispiel des Risk Evaluation for Pensions:
„Through stronger governance IORPs will too improve their decision-making as they are required to prepare a Risk Evaluation. The Risk Evaluation for Pensions will stimulate IORPs to identify, manage and control their risks both in the short- and long-term. The Risk Evaluation should also be proportionate to the nature, scale and complexity of the risks inherent in the IORP’s activities. By making IORPs more aware of their commitments to their beneficiaries, the preparation of the Risk Evaluation will help them make better informed decisions about investments in long-term assets.“
„Recently EIOPA published a consultation paper on further technical work on the holistic balance sheet to gather input from stakeholders. The paper constitutes a further step in EIOPA’s work on a risk-based framework for occupational pension funds. EIOPA is undertaking this work on its own initiative, in its role as independent advisor to the European political institutions.
The consultation paper proposes improved definitions and methodologies to value the holistic balance sheet, covering areas such as the valuation of sponsor support, the benefit reduction mechanisms and discretionary decision-making processes and the definition of contract boundaries.
Most importantly, the paper consults on different possible uses of the holistic balance sheet within a supervisory framework, ranging from an instrument to establish funding requirements to a risk-management and transparency tool to assess the long-term sustainability of IORPs.
The scope of this consultation paper is broader than previous work done by EIOPA in this area. There are indeed various ways to shape a market-consistent and risk-based supervisory framework.
The consultation paper not only considers the holistic balance sheet being used to set solvency capital requirements at the EU level, but also to establish minimum funding requirements and as a risk management tool to assess the sustainability of pension funds.
I would like to emphasise that using the holistic balance sheet as a risk management tool should in my view not be a requirement without consequences. First of all, the outcomes of assessments should be disclosed to raise awareness about the financial situation of the pension fund and, where necessary, stimulate reforms. Secondly, if it was concluded that the pension fund is providing unsustainable pension promises, I believe that national supervisory authorities should be empowered to take supervisory action, using a flexible approach.
We are not promoting an EU ‘one size fits all’ approach. A common prudential regime should have built-in flexibility to deal with a wide range of occupational pension schemes in Member States.
I would like to emphasize that any supervisory framework should in my view be sufficiently flexible to also avoid short-term, pro-cyclical investment behaviour of pension funds during adverse market developments.
It is also essential for me that the holistic balance sheet can be implemented in a proportionate way and without imposing high costs on pension funds. The consultation paper proposes that pension funds with strong sponsors may establish the value of sponsor support as a ‘balancing item’. I am convinced that such an approach will considerably simplify the valuation of the holistic balance sheet for a large number of pension funds. In addition, it provides the right incentives by requiring pension funds with weak sponsors to do more detailed assessments.
The further work on the holistic balance sheet has to be tested through a quantitative assessment. EIOPA expects to publish draft technical specifications for such an assessment by early 2015. Our final aim is to deliver robust, tested proposals to the EU political institutions by the end of 2015, beginning of 2016.“
Zu den offenen Ohren der EIOPA gegenüber Sorgen, Nöten, Ratschlägen und Feedback der relevanten Stakeholder:
„I believe that we showed that we take consultations seriously and that we are ready to listen, discuss and evolve in our proposals, remaining faithful to our vision, but using pragmatic and proportionate solutions.“
„EIOPA is now preparing a pensions stress test. We are taking a two-stage approach: preparatory work in 2014 and running the stress test in 2015.
Our aim is to develop a stress test framework that is appropriate and suitable for pension funds.
An important part of the preparatory work is to gain insight in the role of IOPRs in financial stability. To analyse transmission channels of IORPs to financial markets, EIOPA started a data collection exercise covering a sample of defined benefit, hybrid and defined contribution schemes in Member States with a significant IORP sector.
This exercise will allow us to assess the pro-cyclicality of pension funds investment behaviour during the past decade, including the financial crisis in 2008.
The stress test will assess the resilience and the behaviour of IORPs in adverse market developments, such as a prolonged low interest environment or a sudden material reassessment of risk premia. It will also incorporate stresses in longevity as one of the major risks in pension funds overall financial condition.
Our intention is that the pension stress test will cover IORPs that provide defined benefit schemes as well as the ones that finance hybrid or defined contribution plans. We will conduct the stress test in parallel with the quantitative assessment on the solvency side in order to avoid the duplication of calculations. This will limit to the extent possible the burden on pension funds and supervisory authorities.“
„An important step towards facilitating worker mobility in the EU was taken earlier this year when the European Parliament and the Council adopted the ‘Directive on minimum requirements for enhancing worker mobility by improving the acquisition and preservation of supplementary pension rights’.
The Directive does not foresee any minimum requirements concerning the transferability of supplementary pension rights. Nevertheless, pension transferability remains an important aspect of worker mobility, and Member States are encouraged to improve the transferability of vested pension rights.
In this context, EIOPA received last June a formal Call for Advice from the Commission to provide an overview of the existing arrangements for transfers of acquired supplementary pension rights between occupational pension schemes in different Member States. In addition, the Commission asked EIOPA to highlight any good practices related to the transfers of acquired supplementary pension rights as well as identify the main obstacles/difficulties affecting (or preventing) transfer, both within countries and across borders.
EIOPA will provide its response to the Commission's Call for Advice by the middle of next year.“
Am Folgetag hielt Bernardino auf der EIOPA 4th Annual Conference ebenfalls in Frankfurt eine Rede ähnlichen Inhalts bezüglich der bAV, die jedoch darüber hinaus auch Solvency II behandelte. Sie findet sich hier.
Details zu ihren Vorhaben dokumentiert die EIOPA in ihrem „Multi-Annual Work Programme 2015 – 2017“.
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