The Future of Supplementary pensions in Europe



The European Commission has taken the initiative on pension reform at
EU level. Most recently it tabled on May 11, 1999 a Communication entitled
“Towards a single market for supplementary pensions”. FEFSI very much
welcomes the recom-men-dations of the European Commission. FEFSI, in
particular, welcomes the recognition of investment funds and companies as
suitable pension vehicles by the Commission. FEFSI believes that traditional
(i.e. defined benefit) pension institutions should be allowed to invest freely
in UCITS and other regulated collective investment schemes and urges the
Commission to take all necessary steps to ensure this freedom. The Commission
has recognised the need to guarantee equal treatment between different
occupational pension providers and stated the need to establish a genuine
prudential framework for pension service providers which could involve the
definition of similar rules for well defined products . FEFSI argues that there is
a need to define specific rules for supplementary defined contribution (“DC”)
systems on EU level. Because DC systems may take various forms ranging from
single funds to self-directed pension savings plans with a wide range of
investment options, FEFSI believes that a European pension fund directive
should not prescribe a specific DC system. Instead FEFSI believes that the
envisaged directive needs to address in general qualitative terms the following
key areas with respect to DC pension funds (“DCPF”):

  • Criteria relating to the institutional security of a DCPF
    (approval of pension fund by a competent authority with intervention
    powers, management by asset managers and agents approved in
    the EU which fulfil strict criteria covering responsibility, competence,
    and the managers’ standing), criteria with respect to the structure
    of DCPF (custody of assets with a depository, separation of powers
    between management and depository, prudential investment, risk
    diversification of assets, world-wide investments, limits on pledging
    or assigning assets)
  • Criteria relating to the economic efficiency and security
    of a DCPF
     (possibility to focus investments on equity and real
    estate, risk diversification, roll-up of gains, long-term accumulation
    of the contributions paid for pension provision)
  • Criteria relating to the transparency of a DCPF (regular
    reporting to the supervisory authority and beneficiaries, audited
    yearly accounts)
  • Criteria relating to the flexibility of a DCPF (flexibility of
    payment of contributions and during the pay out/ withdrawal
  • Criteria relating to the portability of a DCPF (right of unlimited
    transferability (or ownership) of plan assets at market value for
    the beneficiary without a loss of retirement income, no waiting
    periods, market value driven valuation to be carried out based
    on rules established by the competent authorities).

ISSN 1367-580x.

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