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The watchdog acknowledged it has been agreed that occupational pensions should remain outside the scope of the review of the capital adequacy regime for the European insurance industry.
But it said: “There remains the question for the future of whether the pensions directive will subsequently be amended to replace references in that directive to the current Solvency 1 directives with updated references to Solvency II, thereby requiring occupational pensions to comply with some or all of the requirements in the new framework.'
It added: 'The Commission's position on this is currently unclear, though a number of other European regulators that have both insurance and pensions in their remit are pushing for this change to be made.'
The comments come in the FSA's latest annual International Regulatory Outlook published today.
'Clearly this would be a very important question for the UK, and we will continue to work together with the Pensions Regulator to try to ensure that the particular operational model of UK occupational pensions is well understood, and that any future prudential changes are appropriate and subject to rigorous cost-benefit analysis.'
The FSA added that the 'volume of regulatory change' would make for a challenging year for asset managers.
It cited three initiatives specifically: the Markets in Financial Instruments (MiFID) and the Capital Requirements (CRD) Directives and UCITS III.
Meanwhile, the Pensions Regulator has released a discussion paper about pension scheme abandonment, following debate about corporate deals which may lead employers to abandon their schemes.
It said: 'After proposals which seek to sever the link between employers and their defined benefit pension schemes were brought to its attention, the regulator has now issued a discussion paper, alongside draft guidance, to help trustees identify such proposals and consider their implications.'
Chief executive Tony Hobman said: 'We recognise that the definition of abandonment may not be clear cut in every case. That is why we believe guidance is needed. It will help trustees identify transactions that may result in abandonment, and guide them on the factors to assess when reviewing the merits of the transaction for scheme members.'