The CEA acknowledges attempts by the Presidency to resolve issues around definitions of pension schemes, but still raises concerns about latest draft documents having only minor differences from previous versions.
As it stands in the current text, pension schemes captured under this definition would be subject to a transitional exemption from central clearing requirements. The CEA continues to be convinced that to protect the retirement income of European pensioners, a level playing field between EU pension providers must be ensured, avoiding unduly disadvantaging any occupational pension providers.
The CEA is pleased to see that the thrust of recitals 15a & 15b go in the right direction, in their opinion, of expanding the scope of the transitional to all entities and arrangements which have the primary purpose of providing income at retirement. This would indeed avoid unintended unlevel playing field. However, the reference in Recital 15b), and Article 2 (23) excluding the occupational retirement business of insurers provided that assets and liabilities are ring-fenced is inappropriate. This would not include the vast majority of retirement schemes provided by insurers.
The CEA also highlights the need to expand the existing list of highly liquid collateral, and supports the exemption for intra-group transactions, as they are useful risk management tools.
Press release
© CEA - Comité Européen des Assurances
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