Peter Vlaar, APG’s head of ALM modelling; Siert Vos, MN’s senior policy adviser; Agnes Joseph of Syntrus Achemea; Niels Kortleve, PGGM’s innovation manager; and Sibylle Reichert of the Pensions Federation, said EIOPA should not treat pension funds like banks or insurance companies. The authors – pointing out that pension funds cannot default and are unleveraged and unburdened by mass withdrawals – denied that the sector posed a contagion risk to other institutions.
	Instead of EIOPA’s assessing European pension funds based on the two adverse market scenarios – proposing a crash in share prices or a rate increase – or an increase in life expectancy, the authors instead proposed ALM studies as a means of providing insight into the impact of stress scenarios on beneficiaries. They argued that the ALM study included a number of calculations, such as future potential benefit levels, that were absent in EIOPA’s calculation.
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