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The UK National Association of Pension Funds (NAPF), Dutch Pensions Federation, the German pension fund association (aba) and PensionsEurope all categorically rejected the HBS project.
The NAPF said that, while it shared EIOPA’s ultimate goal – the financial security of IORPs – it argued that the HBS would fail to achieve this.
It welcomed the additional flexibility granted to national supervisors in the latest HBS proposal but said this undermined the purpose of the project.
“The whole project was originally intended to allow greater comparability of pension schemes through a more harmonised regulatory system,” it said.
“If regulation is to be determined at national level, then there can be no justification for an EU-wide HBS system.”
For its part, the aba said EIOPA faced a dilemma in introducing the HBS, with the supervisor failing to present a concept that was “to any degree satisfactory”.
“If it is sound, it isn’t practical, and if it is workable, its results are questionable,” the German industry group said.
The European Association of Paritarian Institutions (AEIP) argued that the first quantitative impact study from 2012 had shown the “severe practical problems” EIOPA would face in translating its ambition for the HBS into a feasible tool, due to the absence of comparable market data.
“The complexity of the methods to use makes the HBS very sensitive, possibly too sensitive, for model and parameter assumptions, which can result in the valuation of HBS to change by tens of percentage points depending on the assumptions used,” it said.
Respondents were also concerned about the economic impact of the proposals, with the risk sponsors will be forced to increase contributions highlighted in a number of submissions.