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“The current application of the IORP Directive has resulted in variations in national solvency standards, which has in turn lead to regulatory arbitrage between Member States”, the CEA states. This is in marked contrast to the Solvency II proposal, which is intended to bring about consistent and harmonized supervision across the EU, CEA argues.
CEA also criticizes the difficulties in the transferability of pension rights. In a single EU market for pensions, competition should be between providers and variations in scheme characteristics, rather than between supervisory regimes, CEA states.
However, CEA also underlines the importance for the insurance industry that the implementation of Solvency II for insurance companies is not delayed by the debate on pension funds.