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The association expressed "grave disquiet" over the content of the consultation paper on the QIS launched last month by the European Insurance and Occupational Pensions Authority (EIOPA). Paul Kelly, chairman of the ACA's International Committee, denounced the "hideously complex" set of calculations with "little room for professional judgement".
"Indeed", he added, "EIOPA seems to believe there is only a restricted role for actuaries in this process."
Kelly also argued that the QIS failed to assess the "quantitative" aspects of the holistic balance sheet approach and that any assessment of the "main impact" – such as how much extra cash companies would need to contribute – had been left to the European Commission to determine.
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