In its response to EIOPA's report on the HBS in a revised IORP Directive, the DNB said: "They might lead to a decrease in pension targets and the level of guarantees in the Dutch pension system." The DNB said more quantitative impact studies (QIS) would need to be conducted before a decision could be made on the "appropriate way forward". And while it concluded that the available steering instruments for the HBS were "sufficient", it said the results would depend wholly on "uncertain mechanisms", such as sponsor contributions or pension claim cuts.
The Dutch regulator said it was also difficult to interpret the QIS outcomes in the context of a revised IORP Directive. It found "open ends in the technical specifications, leading to substantial differences in assumptions", and claimed EIOPA had failed to take discretionary elements in decision-making rules into account. "As a consequence", it said, "the valuation of mechanisms for security and benefit adjustment is inaccurate within the context of the QIS".
In its opinion, the impact study's technical specifications also fail to take the supervisory framework or supervisory response to specific conditions into account.
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