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The European Federation for Retirement Provision (EFRP) considers that a revision of the IORP Directive would be a major and complex undertaking which currently is untimely and inappropriate.
The Directive already provides for common minimum standards, EFRP states and warns that it would be disproportionate to embark on a legislative process to amend the current Directive simply because of the linkage to the life-insurance Directive or misconceived level playing field arguments.
No such proposal for an amendment should be made without first undertaking an extensive review of the relevant financial and technical data and each
Applying the proposed Solvency II directive to IORPs with regulatory own funds would result in many sponsors withdrawing from defined benefit pensions, and in turn substantially reduced retirement incomes, EFRP argues. It would also cause substantial shifts from equity to bond investment with negative impacts on financial markets.
Response to Consultation - executive summary