Paritarian institutions are active on financial markets
AEIP’s members are paritarian institutions of social protection in the field of pensions & healthcare insurance. They are subject to national social and labour law (SLL) and under national supervision. At the same time they are using financial markets to increase return on investment for achieving a good level of benefits. As institutional investors we support further integration of capital markets.In this respect, we still encounter barriers when investing abroad, due to differences in legal systems or administrative requirements and sometimes to discrimination of foreign investors. Such barriers should be progressively removed. AEIP believes that supervisory convergence can help in this regard. This is not the case if we consider paritarian institutions as institutions with a social objective e.g. in the context of occupational plans the opportunity for supervisory convergence is limited. Convergence of supervisory practices is different in a framework of minimum harmonisation. We support a common supervisory culture in a sense of coordination & share of best practices, but not a supervisory convergence that leads to "a one-size-fits-all" supervisory approach.
ESAs Governance: Proper checks and balances needed
NCAs should stay independent in deciding on the supervisory policy for national paritarian institutions - as pension funds & healthcare insurers - which are based on national SLL. Regarding ESAs’ role, we think that any guidelines/recommendations shall remain non-binding measures.With time guidelines/ recommendations have become "soft regulation" which appears as binding. This state of play shall be reviewed. With regard to capital markets, ESAs can and should play a greater role. Also in this respect, the added value of NCAs needs to be preserved. A right balance needs to be struck between maintaining the NCAs’ current roles and enhancing ESMA’s role in mainly creating more supervisory convergence. For capital markets, we think that there is strength in combining both the national and European factors, rather than replacing the one by the other. We see an important role for the EC, the Council and the EP in the supervision of the ESAs, in order to check whether their operations align with the set responsibilities. The governance structure of EIOPA needs to ensure sufficient knowledge and expertise about specificities of occupational plans or social protection insurance plans (healthcare, death & disability)
Insurance & occupational pension supervision in Europe is mainly in the hands of national supervisory authorities we consider good & independent supervision to be important. However, shifting the funding of the ESAs to the industry is not the right way forward. In this respect it is also important to take into account the triangle between regulators (in this case the EC & national governments), the supervisory authorities and the institutions that are being supervised. Supervisory budgets need to be subject to adequate checks and balances. The budgets of the ESAs needs to be closely monitored by the EU budgetary procedure
-Comparing stress test results between individual IORPs has little added value, since the results should be interpreted within the national supervisory framework – which differs from country to country
-Reducing and streamlining reporting requirements should be high on the priority list. Data, including those for statistical purposes, should only be collected by national NCAs
-We welcome that the ESA Review Package aligns with the Better Regulation Agenda, when implementing and carrying out cost-benefit-analyses should always be the driving force
-A continuous dialogue between supervisor and supervised entities is at the core of efficient and effective supervision
-There should be no bank bias within the ESRB, neither in its approach to other financial sectors nor in its govern
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