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The currently running quantitative impact study (QIS) on the new solvency requirements will only have "restricted significance", and its relevance will be "limited", as the majority of occupational pension schemes in Germany – mainly the smaller ones – "cannot take part because of its complexity", Nellshen warned.
Nellshen stressed the importance of a wide participation among aba's members in order to assess the complexity properly. Nellshen went on to argue that the revised IORP Directive was "based on a copy of Solvency II" and "completely unfit for occupational pension plans".
He repeated criticism voiced by many members of the German and other pension industries that Solvency II's "short-term approach" could distort occupational pension funds' long-term investment horizons. He also pointed out that these pension funds were financed jointly by employers and the capital market.
Nellshen cited the risk-margin is another major problem for occupational pensions that should be removed from the IORP Directive. He said the risk-margin was "not relevant" for the second pillar, as occupational pension schemes, unlike life insurance companies or other listed companies, did not have to create revenue on their equity.
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