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In a draft response to the consultation paper on the QIS launched by the European Insurance and Occupational Pensions Authority (EIOPA) last month, the stakeholders group said the proposed document failed to measure the "real" impact, or shed light on a supervisory prudential framework. Without a prudential framework, it said, it will be unclear how IORPs will react or what the consequences will be for the economy.
The group also warned that the proposed QIS would focus responses on technical details instead of the general concept or practicality of the holistic balance sheet approach. "If this is the only QIS conducted before a revised IORP proposal is introduced by the European Commission, all relevant questions should be directed and clearly answered in one run", it said.
The group recommends that EIOPA begins with the first QIS and then gradually decides whether greater sophistication is needed for a "better process". "More QIS will lead to a higher involvement of the stakeholders and a better understanding by IORPs, the Commission, the Parliament and supervisors on how to deal with a revised IORP Directive", the stakeholders group said, adding that those market players had "very limited" experience with the valuation of adjustment and steering mechanisms.
It also argued that the representativeness of the QIS had been "insufficient" for the implementation of a second IORP proposal, as only eight out of 27 Member States would provide feedback on the revised Directive. The group criticised the fact that municipal and local authority pension funds had not been included in the testing process, despite being "significant" providers of second-pillar pensions.
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