The implications of the proposed revision to the IORP Directive remain as potentially serious as ever, with far reaching consequences for employers, schemes, members and investors.
At the turn of 2011-2012, the European Insurance and Occupational Pensions Authority set out a short period for consultation on the proposals it was intending to make to the European Commission. The overall thrust of the responses was critical of EIOPA's proposed approach. Concern was voiced about the consultation's central assumption - that Solvency II was an appropriate framework for the regulation of funded company schemes.
Macfarlanes outlines the response to EIOPA's proposals and where the draft directive is likely to go from here.
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