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20 January 2012

ICMA(国際資本市場協会)のソルベンシー2ワーキング・グループがEIOPA(欧州保険年金機構)の市中協議書に対するコメントを提出


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The working group believes that Solvency II requirements should take into account the global context in which the asset management industry works in and would urge EIOPA to consider international convergence of regulatory requirements with any other European legal or regulatory requirements.


The Solvency II Directive aims at harmonising and strengthening regulation in the European insurance field. The Directive is planned to come into force in 2014. Insurance companies have already studied Pillars 1 and 2, looking respectively at the quantitative requirements and the supervisory review. The recently announced new deadline will now allow insurance companies to work more specifically on Pillar 3, which focuses on reporting and public disclosure.

Under the impetus of some AMIC members, a specific Working Group dedicated to Solvency II and its impact on services delivered by asset managers to their clients has been established.

  • One part of the project is to agree on some general principles at industry level regarding acceptable disclosure policies in terms of frequency and the timeline of reporting after the month and quarter end.
  • The other relates to simplifying the “look through” into underlying fund holdings. 

Here the idea is to explore the possibility of considering a set of Solvency II compliant risk numbers, whilst taking into consideration the reporting burden for a fund with very large portfolio holdings. Given the lack of clarity in the reporting requirements, an asset management industry approach would help coordinate efforts with other industry groups affected by the changes in Solvency II.

The first meeting was organised on 19 October to gauge how much appetite there was amongst top asset managers to creating a Working Group, and whether there was a real desire from the asset management industry to cooperate on a project that will span across the next two years. The reception was positive and other meetings have been organised to make progress on the project.

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