The amendments will lead to “considerably lower implementation and follow-up costs” than the initial draft by the EC, according to Peter Gramke.
Speaking at the German pension fund association’s (aba) annual conference, Gramke, head of Internal Audit SOKA-BAU, a supplementary pension plan for construction workers in Germany, pointed out that the new proposal no longer contained any delegated acts linking IORP II to other legal frameworks, which “eases the burden considerably – also regarding costs”. He said there were fewer supervisory reporting demands than a year ago and that the Directive, were it to be implemented in its current form, would be a “limited burden” on pension fund costs.
He said the information requirements had been cut considerably, adding that the Commission had “completely underestimated” these costs. Gramke also commended the Italians on changing the wording in the definition of IORPs from financial institutions to “pension institutions with a social purpose that are active on financial markets”. “This is an important distinction that will change regulation over the medium term,” he said.
Dietmar Keller, head of division at German supervisor BaFin, said the requirement to calculate the funding needs and sponsor support would be tantamount to “introducing the holistic balance sheet (HBS) approach via the back door”. He said he was convinced that EIOPA would “continue to work on HBS” and bring it back to the table after the current commissioner’s five-year tenure, if not before.
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