“I would highlight few key areas where the Directive can be improved:
· Role of social partners: The new requirement for ‘professional’ qualifications for ‘all persons who effectively run the institution’ appears to mean the end of member-nominated and employer nominated trustees, undermining social partner (employees and employers) participation in the governance of pension schemes. This could be solved by removing the ‘professional’ requirement. It would also be better to assess governing bodies’ skills collectively. It should also be possible to combine function between the employer and the IORP when needed (for e.g. internal audit).
· Pension Benefit Statement: The standardised two-page Pension Benefit Statement (PBS) would make it more difficult for pension schemes to provide the information their own members need in the format that works for them. Pension schemes have really innovated in recent years and this would make it impossible for them to tailor communications to suit their own members. We call for more flexibility in the implementation of the PBS in order to fit more closely to the different pension promises.
· Cross-border schemes: We had hoped the new Directive would remove the current, very demanding, requirement for cross-border pension schemes to be fully funded at all times, but this has been omitted. This positive change would be a useful addition to the text.
· Costs: The Directive would impose significant extra costs on pension schemes at a time when governments are seeking to bear down on pension charges. We highlight the balance between costs and added value for members and/or beneficiaries is crucial as members and employers will be the ultimate payers.
· Delegated acts: Pension technical issues are highly political. Therefore pension regulation should be decided at Level 1.
· Depositary: The appointment of a single depositary should not be mandatory if there is already one in the investment chain.”
Full speech
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