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PensionsEurope’s statement came in a position paper summarising its response to EIOPA’s consultation paper on the Holistic Balance Sheet. The consultation was published on 13 October 2014 on EIOPA’s own initiative. Although PensionsEurope recognises that EIOPA as addressed some of the issues raised during previous rounds of consultations, the HBS still contains many shortcomings and is not suitable as a regulatory instrument at EU level. PensionsEurope warns that the HBS would place unacceptable burdens on IORPs and their sponsoring undertakings and would have detrimental effects for millions of EU citizens.
Matti Leppälä, PensionsEurope Secretary-General and CEO said: “PensionsEurope thinks that the Holistic Balance Sheet concept is conceptually wrong as an instrument for setting capital requirements. We think it cannot be used as a supervisory instrument at EU level. Furthermore, the HBS is extremely difficult to calculate and relies on too many assumptions, which makes its use as a transparency tool very questionable.”
Joanne Segars, Chair of PensionsEurope said: “The Holistic Balance Sheet would have negative impacts at both micro and macroeconomic levels. We are very worried that it would increase the cost of funding adequate and sustainable pensions. “PensionsEurope is warning that EIOPA’s proposals run counter to the European Commission’s policies of building a Capital Markets Union and channeling more private (pension) savings into long-term and job-creating investments. It is increasingly clear that the European Commission has no plan to take forward the Holistic Balance Sheet, so we do not see why EIOPA is continuing with this work. PensionsEurope urges EIOPA to put the HBS project aside and focus on the areas where it could make a positive difference.”