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	<title>Jeremy Woolfe</title>
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		<pubDate>Wed, 28 Sep 2011 14:38:55 +0000</pubDate>
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		<title>Suspected Prips watering down disappoints reformers</title>
		<link>http://jeremywoolfe.be/2011/06/05/suspected-prips-watering-down-disappoints-reformers/</link>
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		<pubDate>Sun, 05 Jun 2011 16:20:40 +0000</pubDate>
		<dc:creator>Fefaine</dc:creator>
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		<description><![CDATA[By Jeremy Woolfe Published: June 5 2011 11:20 &#124; Last updated: June 5 2011 11:20 Reformist groups fear that July’s scheduled publication of the European Commission’s proposals for the forthcoming Packaged Retail Investment Products (Prips) directive will reveal a heavily &#8230; <a href="http://jeremywoolfe.be/2011/06/05/suspected-prips-watering-down-disappoints-reformers/">Continue reading <span class="meta-nav">&#8594;</span></a>]]></description>
			<content:encoded><![CDATA[<div><a rel="attachment wp-att-595" href="http://www.jeremywoolfe.be/wp/2011/06/suspected-prips-watering-down-disappoints-reformers/ftheader/"><img class="alignleft size-full wp-image-595" src="http://www.jeremywoolfe.be/wp/wp-content/uploads/2011/06/ftheader.jpg" alt="" width="685" height="60" /></a></div>
<p>By Jeremy Woolfe</p>
<p>Published: June 5 2011 11:20 | Last updated: June 5 2011 11:20</p>
<div>
<p>Reformist groups fear that July’s scheduled publication of the European Commission’s proposals for the forthcoming Packaged Retail Investment Products (Prips) directive will reveal a heavily watered-down document. They suspect the legislation will be a shadow of former intentions and narrower in scope.</p>
<p>The Prips directive was originally planned to cast light on the sales practices used for retail products, ranging from annuities to life insurance and managed funds. Part of its focus was to rein in hidden sales commissions and other sales malpractices.</p>
<div>
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<div>The scale of the ethical issue is so widespread that it calls for political intervention, according to Agnes Le Thiec, head of the Brussels office of the CFA Institute.</div>
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<p>However another French national, Guillaume Prache, managing director of EuroInvestor, a Brussels-based lobby group representing small investors, fears that in the end, the “intervention” will, as the French saying goes, turn out to be like a mountain (of effort) giving birth to a mouse, despite a gestation period dating back to 2007.</p>
<p>The volume of investment potentially liable to the proposed directive – in the form of investment funds, unit-linked life investments, structured retail securities and deposits – adds up to something like €13,000bn, with investment funds the dominant element.</p>
<p>Mr Prache tells FTfm that the original “broad scope” intended by retail investor groups for Prips was to help and encourage retail investors to invest with confidence. The groups’ target for the directive was to provide sales disclosure and sales practice rules for everything, including listed shares, bonds and other fixed income securities such as bank certificates of deposit, commercial paper, and government treasury bills, as well as packaged products.</p>
<p>Also to be included were traditional life insurance, savings accounts, non-mandatory pensions subscribed to by the individual, annuity products and some derivatives, as long as they are regularly sold to retail investors. But now, Mr Prache believes, the Commission appears to be on track to exclude most bank savings products, all personal pension investment products (which can sometimes lock-in a customer for decades) and the bulk of life insurance contracts.</p>
<p>While life insurance may technically be included, in France, for example, the Commission is likely to exclude from the scope of the proposed legislation all but unit-linked life insurance policies, where investments are wrapped up, or packaged, in an insurance policy.</p>
<p>In other words, the big market of straight life policies, worth €1,200bn in asset value, would be excluded, with only policies with a value of €200bn remaining within the scope of the directive.</p>
<p>Mr Prache argues the evidence for the heavy dilution of the original aspirations is clear from the wording of the Commission’s recent consultation paper. The Commission itself says it is currently “finalising its proposals” on the basis of feedback from interested parties.</p>
<p>Mr Prache’s position is supported by EuroShareholders, the European Federation of Financial Advisers and Financial Intermediaries (FECIF) and the Association of International Life Offices.</p>
<p>The UK’s Investment Management Association takes a roughly similar view, but it does not ask to have savings accounts or individual equities or bonds included.</p>
<p>The blame for any weakening of the proposed legislation is placed on opposition by other interest groups to a crucial part of the exercise, the Key Investor Information Document (Kiid). Under this, the seller has to provide a potential customer with a standardised form, comprising a list of mandatory information written in simple language, on not more than two pages.</p>
<p>One opponent of a universal Kiid is the European Banking Federation, which does not believe that such a document should be required for all types of packaged retail investment products, given the important differences between products.</p>
<p>The forecast enfeeblement of Prips from its original intention is “disappointing”, according to Peter de Proft, director general of the European Fund and Asset Management Association. He criticises the Commission’s decision to split the regulation of product disclosure from the rules concerning sales practices.</p>
<p>Rules on distribution concerning insurance, in the Insurance Mediation directive, will be reviewed and aligned with the existing Markets in Financial Instruments directive, or Mifid, but a proposal for the IMD is not expected until late this year. Rules applying to sales practices of other investment products will remain covered by Mifid, which is also under review. Here, revision has been delayed from July to the autumn.</p>
<p>The danger is a legislative “Balkanisation”, or a divergence between the master legislation and technical measures, as set, at a lower level, by sectorial regulators.</p>
<p>A further lack of harmonisation could ensue given that three different European supervisory authorities will be involved. Depending on the financial product being sold, the relevant supervisor will either be the European Securities and Markets Authority, the European Banking Authority or the European Insurance and Occupational Pensions Authority, says Mr de Proft.</p>
<p>Regarding the scope of Prips, Efama largely agrees with the Commission but disagrees with the decision to exclude all pension products. It argues that all insurance products with an investment element should be included.</p>
</div>
<p><a href="http://www.ft.com/servicestools/help/copyright">Copyright</a> The Financial Times Limited 2011. You may share using our article tools. Please don&#8217;t cut articles from FT.com and redistribute by email or post to the web.</p>
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		<title>Pensions terminology is a confusing mishmash and needs to be simplified.</title>
		<link>http://jeremywoolfe.be/2011/01/19/ipe-investment-pension-europe/</link>
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		<pubDate>Wed, 19 Jan 2011 13:51:36 +0000</pubDate>
		<dc:creator>Fefaine</dc:creator>
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		<description><![CDATA[&#160; Jeremy Woolfe asks whether it is causing problems not just for legislators but for all those who are pushing toward comparability in the finance and pensions industries. A meeting involving different EU nationalities might waste time untangling definitions. Direct translations &#8230; <a href="http://jeremywoolfe.be/2011/01/19/ipe-investment-pension-europe/">Continue reading <span class="meta-nav">&#8594;</span></a>]]></description>
			<content:encoded><![CDATA[<p style="text-align: justify">&nbsp;</p>
<p style="text-align: justify"><em>Jeremy Woolfe asks whether it is causing problems not just for legislators but for all those who are pushing toward comparability in the finance and pensions industries.</em></p>
<p style="text-align: justify">A           meeting involving different EU nationalities might waste time           untangling definitions. Direct translations from one language to           another do not overcome the confusion because terms are so different.</p>
<p style="text-align: justify">Tday’s           situation has parallels with the mythical Tower of Babel. Genesis,           Chapter 11, holds as an ideal that “the whole earth was of one           language, and of one speech”. However, the ideal broke down. This           was God’s retribution for hubris, entailed in the construction <a rel="attachment wp-att-204" href="http://www.jeremywoolfe.be/wp/2011/01/ipe-investment-pension-europe/tower-of-babel/"><img class="alignright size-full wp-image-204" src="http://www.jeremywoolfe.be/wp/wp-content/uploads/2011/06/tower-of-babel.gif" alt="" width="283" height="220" /></a>of           the tower “who’s top may reach unto heaven”. The result was           “language being confounded&#8230; that [people] may not understand one           another’s speech.” The comparison with pension terminology is apt.</p>
<p style="text-align: justify">Chris           Verhaegen, secretary general of the European Federation for Retirement           Provision (EFRP), suggests that the first step towards a solution           should be agreeing a common EU criteria. These should be collated in a           table for comparison purposes, in other words, ‘a complete           mapping’ of the various systems. In its official response to the           European Commission’s green paper on pensions, the EFRP proposes           “a matrix on European pension systems”.</p>
<p style="text-align: justify">The           matrix would allow member states “to fit their pension systems into           a European template”. Once the systems were mapped, discussion on           categorising them as “social security arrangements” or “social           protection schemes” could begin. The boundaries between the           different layers, or tiers, of retirement income could be clarified at           an EU-level based on commonly agreed indicators for each tier.</p>
<p style="text-align: justify">However,           Verhaegen admits that creating the matrix would not be easy. “It           would be optimistic to think it could be done in a year,” she           comments. She cites first and second pillars as one example of the           confused definitions.</p>
<p style="text-align: justify">Another           example is the term pension itself, which in some member states is           only defined from a fiscal perspective. Verhaegen says that although           the matter has caught the attention of the EU Council progress is           slow.</p>
<p style="text-align: justify">An           official at the European Commission confirms that pensions           professionals have difficulty in agreeing measurement rules between           jurisdictions. Even when so called equivalent standards are supposedly           in use, he says few co-ordinate properly.</p>
<p style="text-align: justify">The           route ahead, says the official, must lie with adopting and developing           an eXtensible Business Reporting Language (XBRL). XBRL, he continues,           “would force harmony across different concepts and definitions used           by professional practices in different EU jurisdictions.” He says it           is essential that the supervisory organisations, such as the European           Systemic Risk Board (ESRB) and the ECB, achieve “archive harmony”.</p>
<p style="text-align: justify">XBRL           is a computer language used to describe financial data. Dating back to           1999, it is managed by a non-profit consortium, XBRL International.           XBRL’s technicalities are complex. Its communications systems are           defined by sets of metadata, which are established in taxonomies.</p>
<p style="text-align: justify">Taxonomies           include the definition of individual reporting elements and the           relationships between different elements. For pensions, the first           challenge is to agree common ‘tags’ to match definitions. Tags are           computer readable sets of data that go towards the processing of           financial statements.</p>
<p style="text-align: justify">In           Europe, the official says, the take-up of XBRL is, so far, most           advanced in the banking sector, which has been using the taxonomies           since 2005. At least 12 financial authorities are now demanding it, or           allowing it. Gilles Maguet, secretary general of XBRL France, notes           that banks in half of the EU are using XBRL to apply Basel III rules.</p>
<p style="text-align: justify">Although           Maguet says that adoption by the pension world is “a bit late”,           progress in the insurance industry – driven partly by the Solvency           II – has been of benefit to pensions accounting.</p>
<p style="text-align: justify">Upgrades           would enable the insurance and pension investment firms to be able to           communicate better with authorities such as the Insurance and           Occupational Pensions Authority (EIOPA). The authority took over from           Committee of European Insurance &amp; Occupational Pensions           Supervisors (CEIOPS) on 1 January.</p>
<p style="text-align: justify">Last           year, CEIOPS stated that, for insurance, the taxonomy is still being           worked out. A binding solution is scheduled for early 2013.</p>
<p style="text-align: justify"><strong> </strong> <a href="http://www.ipe.com/"><img class="alignleft size-full wp-image-192" src="http://www.jeremywoolfe.be/wp/wp-content/uploads/2011/06/journa9.jpg" alt="" width="381" height="86" /></a>From IPE Com (news)</p>
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		<title>Pensions chief hits out at possible extension of Solvency II to plans</title>
		<link>http://jeremywoolfe.be/2011/01/16/pensions-chief-hits-out-at-possible-extension-of-solvency-ii-to-plans/</link>
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		<pubDate>Sun, 16 Jan 2011 13:35:59 +0000</pubDate>
		<dc:creator>Fefaine</dc:creator>
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		<description><![CDATA[EU legislation Philip Neyt says such a move would defy logic, reports Jeremy Woolfe. Harsh criticism of forthcoming EU rules that may force European Union pension fund managers to move further from equities into bonds comes from the chairman of &#8230; <a href="http://jeremywoolfe.be/2011/01/16/pensions-chief-hits-out-at-possible-extension-of-solvency-ii-to-plans/">Continue reading <span class="meta-nav">&#8594;</span></a>]]></description>
			<content:encoded><![CDATA[<p style="text-align: justify"><strong>EU           legislation</strong></p>
<p style="text-align: justify"><span style="font-size: medium"><strong><em>Philip           <strong>Neyt</strong> says such a move would defy logic</em>, reports Jeremy<strong> Woolfe.</strong></strong></span></p>
<p style="text-align: justify">Harsh criticism of forthcoming EU rules that           may force European Union pension fund managers to move further from           equities into bonds comes from the chairman of the Belgian Association           of Pension Institutions. Philip Neyt says the probability confounds           logic. “I am very worried. The authorities should be pushing for           moves in exactly the opposite direction.”</p>
<p style="text-align: justify">Mr Neyt blames the intended, but as yet           unconfirmed, move by the European Commission to apply Solvency II           rules to pension funds as highly damaging both to the interests of           future retirees, and to the European economy as a whole. He describes           the push as well intentioned, but obsessively based on historic           models.</p>
<p style="text-align: justify">Yes, Mr Neyt admits, equity performance may           have been poor during the past 10 or so years. But today’s problem           is different. Now we face the threat of a <a title="FT.com / Markets - The hidden dangers of passive bond investing" href="http://www.ft.com/cms/s/0/7230b124-1dab-11e0-aa88-00144feab49a.html#axzz1BC9uEcfh">bubble           in bonds</a>. “Furthermore, if we lock ourselves into low returns,           and then hit higher inflation, we shall be in real trouble,” he           says. Herd behaviour could put further pressure on yields, resulting           in lower pension income.</p>
<p style="text-align: justify">However, he continues, who can be sure of what           the future holds? Logically, the standard setters should be           encouraging the principles of investing by common sense. In practice,           this would mean applying pressure away from bonds and into equities.           In any case, they should hold back on rules.</p>
<p style="text-align: justify">The logic behind the position of Mr Neyt, who           is also chief executive of the pension fund for Belgacom, the Belgian           telecoms group, rests on the fact that pension fund managers are           seeking to cover liability obligations perhaps 25 years, or more, from           the present. Compared with this, bonds are in fact “short-term           instruments”, he says. And, at present, their return is a low 3-4           per cent, not far above inflation, thus risking the value of future           assets.</p>
<p style="text-align: justify">The background to Mr Neyt’s protest is           forthcoming EU legislation that could bring occupational pension           schemes (known in EU jargon as institutions for occupational           retirement provision, or Iorps) under the Solvency II rules in the           process of being applied to life insurance companies. The official           logic is to create a prudential level playing field between different           sectors, including banks and insurance companies, that invest for           future pensions.</p>
<p style="text-align: justify">Solvency II rules set capital requirements           based on an institution’s exposure to risky assets, in a similar way           to the Basel II rules that apply to banks. More capital is needed to           back equity holdings than bond holdings. For each holding in equity of           about €100, institutions need a capital buffer of nearly €40,           which is unnecessary for government bonds. Funding by employers would           have to rise significantly, says Mr Neyt.</p>
<p style="text-align: justify">Overall, funded pension schemes and life           insurance policies amount to more than €10,000bn ($13,200bn) of           assets at EU level. This represents half of total long-term household           savings. Of the €10,000bn, €3,700bn is invested via occupational           pension schemes, says Mr Neyt, and an average 40 per cent is in           equities. If the Solvency II rules do get extended to these schemes,           €1,200bn of the equity holdings would have to be sold off.</p>
<p style="text-align: justify">His second line of protest is damage to the           European economy resulting from the withdrawal of thousands of           billions of euros by pension investors.</p>
<blockquote><p>If we lock ourselves into low returns and hit higher inflation, we shall be in trouble.</p></blockquote>
<p style="text-align: justify">Similar alarm is echoed by MiddleNext, the           Paris based association for mid-cap firms in France. Its secretary           general, Caroline Weber, says Solvency II is already resulting in           reduced equity investments by insurance companies in mid-cap           companies. The proportion of assets under management held in the           sector by insurance companies is on its way down from 20 per cent to           an expected 3 per cent.</p>
<p style="text-align: justify">The European Commission’s head of unit for           insurance and pension financial institutions, Karel Van Hulle, holds           the general view that “the issue is not that simple”. He says the           legislative situation “is still [in] the realm of speculation”. He           suggests pension fund managers should “continue diversifying their           portfolio of investments”.</p>
<p style="text-align: justify">However, Mr Van Hulle concludes with the           somewhat barbed question: “Who will protect the members or the           policyholders if the pension fund or insurance company has put all or           most of its investments in very risky assets?”</p>
<p style="text-align: justify"><strong>Copyright</strong> © The           Financial Times  Limited 2010. You may share using our article tools.           <a rel="attachment wp-att-225" href="http://www.jeremywoolfe.be/wp/2010/05/change-in-brussels-top-staff-raises-eyebrows/journa8/"><img class="alignleft size-full wp-image-225" src="http://www.jeremywoolfe.be/wp/wp-content/uploads/2010/05/journa8.jpg" alt="" width="191" height="97" /></a>Please  don&#8217;t cut articles from FT.com and redistribute by email or            post to the web.</p>
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		<title>EU Looks at Stricter Audit Rules</title>
		<link>http://jeremywoolfe.be/2010/12/20/eu-looks-at-stricter-audit-rules/</link>
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		<pubDate>Mon, 20 Dec 2010 13:59:44 +0000</pubDate>
		<dc:creator>Fefaine</dc:creator>
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		<description><![CDATA[In a recent speech, a senior European Commission official warned accountants that a drastic tightening of auditing rules in the European Union is under consideration in Brussels, including possible segregation-of-service rules on client auditing and accounting services, and requiring auditors &#8230; <a href="http://jeremywoolfe.be/2010/12/20/eu-looks-at-stricter-audit-rules/">Continue reading <span class="meta-nav">&#8594;</span></a>]]></description>
			<content:encoded><![CDATA[<p style="text-align: justify"><a rel="attachment wp-att-210" href="http://www.jeremywoolfe.be/wp/2010/12/eu-looks-at-stricter-audit-rules/journa10/"><img class="alignnone size-full wp-image-210" src="http://www.jeremywoolfe.be/wp/wp-content/uploads/2011/06/journa10.jpg" alt="" width="361" height="64" /></a></p>
<p style="text-align: justify">In a recent speech, a senior European Commission official warned           accountants that a drastic tightening of auditing rules in the           European Union is under consideration in Brussels, including possible           segregation-of-service rules on client auditing and accounting           services, and requiring auditors to give &#8220;an unencumbered opinion           of a situation&#8221;, as opposed to the current &#8220;historical           review.&#8221;</p>
<p style="text-align: justify">At a mid-December meeting the European Federation of Accountants, or FEE,           in Brussels to discuss a European Commission public consultation           process on audit policy, members heard Jonathan Faull, a director           general at the commission, refer to &#8220;complacency&#8221; in the           auditing sector, which he described as &#8220;out of tune with the           present times&#8221;.</p>
<p style="text-align: justify">Faull reports directly to Commissioner Michel Barnier, the head of the           department that proposes much of the new financial legislation for the           European Union, who launched the current move to scrutinize auditing           with a &#8220;green paper&#8221; on audit policy in the fall of 2010.</p>
<p style="text-align: justify">Faull went on to elaborate on the present spirit of the Brussels           institution: &#8220;The crisis may have been global, but it did start           in the financial sector, and it is causing misery all over           Europe&#8221;.</p>
<p style="text-align: justify">Hence, the commission&#8217;s position was that today&#8217;s &#8220;status quo is not           acceptable&#8221;.  Faull said that there are still gaps in the           regulatory system that need filling, adding, &#8220;We hope to have a           new set of regulations which we hope will remain in place for a           generation.&#8221;</p>
<p style="text-align: justify">Later, during question time, when some of the questioners exhibited a           decidedly barbed reaction to Faull&#8217;s approach, he noted a link between           the financial crisis and auditing lapses in the banking industry.</p>
<p style="text-align: justify">In his main discourse, Faull fleshed out a series of radical proposals           now under consideration by the commission. These included rules           governing the independence of the auditor. (In an explanatory paper           elsewhere, the commission expands on this theme, noting its           investigation into possible &#8220;conflicts of interest&#8221; when a           firm both audits a company&#8217;s results and offers it consultancy           services to the same firm. In the U.S., the Sarbanes-Oxley Act of 2002           explicitly listed the services that auditors could not offer clients.)</p>
<p style="text-align: justify">At the Brussels meeting, panelists suggested that the auditors should be           appointed by company audit committees, rather than by the main board           of directors. However, Faull went further, airing the possibility that           the right to appoint an auditor should perhaps be placed with an           independent organization. This would remove the right of appointment           from the firm subject to audit.</p>
<p style="text-align: justify">The possibility, described later by one delegate to the meeting as           &#8220;aggressive&#8221;, was defended by Faull as &#8220;necessary&#8221;           in the light of &#8220;professional skepticism&#8221; from investors.           (In its paper, the commission refers similarly to an &#8220;expectation           gap&#8221; between auditors and stakeholders.)</p>
<p style="text-align: justify">Faull&#8217;s comments came as part of the commission&#8217;s intention to a review           its Statutory Audit Directive of 2006. This legislation was mandated           for transposition into the national codes of the EU&#8217;s 27 member states           by 2008. In fact, some countries delayed adoption until this year.</p>
<p style="text-align: justify">The current assessment started off with Barnier&#8217;s &#8220;green&#8221;           policy paper, issued in the fall of 2010. Among the more radical           possibilities raised in the paper were a blanket prohibition on           non-audit services, mandatory rotation of auditors, and having a third           party assign auditors. An astonishingly high number of comments,           estimated at 800, illustrates the heat building up from some           stakeholders. A commission digest of the responses is due in February           2011.</p>
<p style="text-align: justify">This is to be followed by a formal commission position, expected by           mid-2011. Its proposals would then be debated, and, no doubt, amended,           by the European Parliament, during the rest of the year. Any lobbying           could normally be expected during this period. Any revised           legislation, which would also require clearance by national           governments, could be in force in 2013, or later, depending on           resistance.</p>
<p style="text-align: justify">Some reactions to the policy paper have been made public. One instance is           FEE&#8217;s own answer to the green paper&#8217;s question, &#8220;Are audits fit           for purpose?&#8221; Interestingly, FEE noted that audits are           &#8220;currently not explicitly providing comfort on companies&#8217;           financial health, which seem more future-oriented.&#8221;</p>
<p style="text-align: justify">A comment letter from the U.S.-based Center for Audit Quality also noted           a disconnect between what financial statement users think auditors are           providing, and how auditors themselves view their role &#8211; but warned           the commission not to go too far with radical measures to boost           auditor independence, and not to revise auditors&#8217; reports to the point           where they diverge significantly from those in other parts of the           world.</p>
<p style="text-align: justify">From Source  Media, New           York, read mainly in USA.</p>
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		<title>Change in Brussels top staff raises eyebrows</title>
		<link>http://jeremywoolfe.be/2010/05/03/change-in-brussels-top-staff-raises-eyebrows/</link>
		<comments>http://jeremywoolfe.be/2010/05/03/change-in-brussels-top-staff-raises-eyebrows/#comments</comments>
		<pubDate>Mon, 03 May 2010 14:03:52 +0000</pubDate>
		<dc:creator>Fefaine</dc:creator>
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		<description><![CDATA[Jeremy Woolfe looks at what’s behind the removal of two experts in financial legislation The European Commission’s internal markets directorate-general is handling a surge of financial legislation in the aftermath of the financial crisis. So it may not be the &#8230; <a href="http://jeremywoolfe.be/2010/05/03/change-in-brussels-top-staff-raises-eyebrows/">Continue reading <span class="meta-nav">&#8594;</span></a>]]></description>
			<content:encoded><![CDATA[<p style="text-align: justify"><em><strong><span style="font-size: medium">Jeremy             Woolfe</span></strong><span style="font-size: medium"> looks at what’s behind the removal of two experts in financial             legislation</span></em></p>
<p style="text-align: justify">The             European Commission’s internal markets directorate-general is             handling a surge of financial legislation in the aftermath of the             financial crisis.</p>
<p style="text-align: justify">So             it may not be the best time to be losing two of its most senior             officials. But both <a title="Wright man for tough FSA job" href="http://www.ft.com/cms/s/0/5bba3442-16ae-11df-aa09-00144feab49a.html">Jörgen             Holmquist, director-general, and David Wright, deputy             director-general</a>, will leave for academia before the             summer</p>
<p style="text-align: justify">Mr             Holmquist, a Swedish national appointed to his current post in             January 2007, is to take up a fellowship at Harvard University,             while Mr Wright, a Briton, is heading for Oxford University after 33             years with the Commission.</p>
<p style="text-align: justify">Jonathan             Faull, another Brit, will take over as director general, moving from             the Commission’s legal service, where he occupies a parallel             position. Mr Faull’s background is predominantly a legal one, in             contrast to the two departing officials, who have developed their             expertise in financial legislation over years of service.</p>
<p style="text-align: justify">The             mechanics of the staff shuffle are that the European Union             governments, meeting behind closed doors, as always, opted for a             French Commissioner for the Commission division that deals with             financial legislation. They chose Michel Barnier, former EU             Commissioner for regional issues.</p>
<p style="text-align: justify">While             he has been described as unlikely to instill fear in the hearts of             City of London bankers, the British demanded that one of their             nationality take the next highest post. This insistence lead to the             forthcoming demise of Mr Holmquist.</p>
<p style="text-align: justify">Mr             Wright, was the obvious successor as director general, and fits the             unwritten rule in Commission circles that prevents a concentration             of the same nationality in any particular sector.</p>
<p style="text-align: justify">However,             he was ruled out for being, according to the common Brussels view,             “too European” for the British government to stomach. Many of             the division’s 130 financial legislators view the situation with             cynicism.</p>
<blockquote><p>‘The             remarkable’ situation is not the way to run the Commission during             time of crisis.</p></blockquote>
<p style="text-align: justify">they               admire Mr Wright’s expertise. One example of his outspokenness               came up recently when he was addressing European bankers.</p>
<div style="text-align: justify">
<p>He               remarked that the financial crisis is costing European society a 6               per cent drop in gross domestic product, plus high unemployment               with the loss of 10m jobs.</p>
<p>He               also noted that European governments now have to contribute 12 per               cent of GDP to propping up banks.</p>
</div>
<p style="text-align: justify">“In             the end, there is going to have to be more capital in the banking             sector,” he said.</p>
<p style="text-align: justify">This             is not what the members of the European Banking Federation wanted to             hear.</p>
<p style="text-align: justify">Mr             Wright’s departure is described as a shock to many people by Peter             Skinner, a British member of the European Parliament, who is active             in the insurance sector of financial legislation. Mr Skinner feels             the UK is losing someone with significant influence in the EU.</p>
<p style="text-align: justify">“He             understands the broader landscape of EU effort, which is necessary             for markets to be competitive on a global basis,” he says.</p>
<p style="text-align: justify">He             also notes Mr Wright’s leadership role, and the pressure he has             been applying to maintain liaison between financial regulators in             the EU and the US. He hopes Mr Wright’s move “will not be the             end to his contribution to the EU”.</p>
<p style="text-align: justify">Mr             Holmquist’s departure has resulted in newspaper complaints of             weakness by the Swedish government in its failure to defend the             position of their most senior national official in the European</p>
<p style="text-align: justify">Commission.             Gunnar Hökmark, a centre right Swedish MEP, says the             “remarkable” situation is not the way to run the Commission             during a time of crisis, or any other time.</p>
<p style="text-align: justify"><strong>Copyright</strong> © The           Financial Times  Limited  2010. You may share using our article tools.           <a rel="attachment wp-att-225" href="http://www.jeremywoolfe.be/wp/2010/05/change-in-brussels-top-staff-raises-eyebrows/journa8/"><img class="alignleft size-full wp-image-225" src="http://www.jeremywoolfe.be/wp/wp-content/uploads/2010/05/journa8.jpg" alt="" width="191" height="97" /></a>Please  don&#8217;t cut  articles from FT.com and redistribute by email or            post to  the web.</p>
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		<title>IORPs back on agenda</title>
		<link>http://jeremywoolfe.be/2010/05/01/iorps-back-on-agenda/</link>
		<comments>http://jeremywoolfe.be/2010/05/01/iorps-back-on-agenda/#comments</comments>
		<pubDate>Sat, 01 May 2010 14:14:00 +0000</pubDate>
		<dc:creator>Fefaine</dc:creator>
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		<category><![CDATA[pension]]></category>

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		<description><![CDATA[A planned wide-ranging green paper on the state of pensions in the EU is causing anxiety in the industry. The ‘holistic’ approach of the European Commission policy paper – due to be presented in the summer – could throw into &#8230; <a href="http://jeremywoolfe.be/2010/05/01/iorps-back-on-agenda/">Continue reading <span class="meta-nav">&#8594;</span></a>]]></description>
			<content:encoded><![CDATA[<p style="text-align: justify">A planned wide-ranging green paper on the state of  pensions in the EU is causing anxiety in the industry. The ‘holistic’  approach of the European Commission policy paper – due to be presented  in the summer – could throw into question the current ceasefire over the  solvency issue for the Occupational Retirement Provision Directive  (IORPs).</p>
<p style="text-align: justify">Also, the paper will set the scene for a future directive on  defined contribution schemes. But its policy would include attention to  “proper disclosure of investment policy” as Karel Van Hulle, insurance  maestro in the European Commission has confirmed. Van Hulle was speaking  at a recent Brussels conference run by the European Federation of  Retirement Provision.</p>
<p style="text-align: justify">Also lurking in the background is Solvency II, which  modernises capital reserve requirements for insurance companies. Not due  for final implementation into national law until the end of 2012, the  directive is currently being fleshed out through level-two implementing  measures.<br />
More to the point, Solvency II’s relevance to IORPs is still  alive. Although Solvency I rules are referenced in Article 17 of the  IORP Directive to retain the status quo, this will be reviewed. Roger  Koch, senior EU legal analyst at Aegon – the life insurance, pensions  and long-term savings and investment products group – points out that  the IORP solvency rules currently apply only where investment or  biometric risks are borne by the IORP itself.<br />
What is unclear is how exclusion arrangements from Article 17–  where the employer meets any shortfalls – will be dealt with. They  currently fall outside any EU solvency regime. If this carve-out is  retained, any new EU solvency rules would leave employer-backed schemes  such as those in the UK unaffected. Koch says: “EU thinking seems to be  ready to accept national diversity for funded pensions, particularly  regarding the workplace. It aims to create a solvency regime that caters  for this.”<br />
Koch finds EU pensions legislation “complex and fragmented”.  He says: “If the EU is going to tackle this, it also needs to understand  how its rules, particularly in financial services, can better dovetail  with member state social and consumer protection requirements. Pension  diversity must be respected, but its interaction with internal market  rules must also be more transparent and manageable.”<br />
Comment by the pension industry is exceptionally mute; one  organisation said there was no issue, while another gave support to a  feeling of nervousness, but was reluctant to react until the green paper  is published.<br />
With pensions across the EU provided by a number of sectors –  insurance companies, banks, and mutual funds – and with the obvious  pressures to secure a level playing field, it is worth looking at  Solvency II.<br />
Pension fund managers may not consider themselves to be  directly in the firing line. Nonetheless, the recommendation by the  Committee of European Insurance and Occupational Pensions Supervisors  (CEIOPS) to tighten up on capital reserves, which are to be specified in  level-two procedures of Solvency II for insurance companies, appears  likely to have knock-on effects.<br />
An official at the Commission said that when it presents its  policy paper later this year, it does not expect to comply with the  CEIOPS’ ‘conservative’ recommendation. “What we want is a carefully  calculated set of capital requirements. The Commission wants a balanced  system,” he said.<br />
Exactly how insurance companies have to organise their capital  reserves is described by Jacqueline Lommen, manager of pan-European  funds at the Amsterdam office of Hewitt Associates. Pre-Solvency II  control of capital reserves, she explains, involves a cap on how much of  their reserve capital insurance companies may place in specified risk  sectors. Depending on national rules, the upper limit might be 20% in  equity, 5% derivatives, and so on.<br />
Under Solvency II’s risk-based system, companies are being  excused these caps. However, the rules penalise exposure to risk in  different categories of asset (and liability) management. How the  Commission’s forthcoming policy paper will shape up is hard to guess.  One problem could be the conflict between legislators presumably aiming  for a ‘fair-play’ version of the IORPs II, and political officials  presumably aiming to smooth over pressures from 27 diverse national  governments.</p>
<p style="text-align: justify"><a rel="attachment wp-att-192" href="http://www.jeremywoolfe.be/wp/2011/01/ipe-investment-pension-europe/journa9/"><img class="alignleft size-full wp-image-192" src="http://www.jeremywoolfe.be/wp/wp-content/uploads/2011/06/journa9.jpg" alt="" width="381" height="86" /></a></p>
<p style="text-align: justify">&nbsp;</p>
<p style="text-align: justify"><strong><span style="font-size: small">©           copyright rules apply</span></strong></p>
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		<title>Solvency II: What CIOs need to know</title>
		<link>http://jeremywoolfe.be/2010/03/22/solvency-ii-what-cios-need-to-know/</link>
		<comments>http://jeremywoolfe.be/2010/03/22/solvency-ii-what-cios-need-to-know/#comments</comments>
		<pubDate>Mon, 22 Mar 2010 14:17:37 +0000</pubDate>
		<dc:creator>Fefaine</dc:creator>
				<category><![CDATA[New articles]]></category>
		<category><![CDATA[Solvency II]]></category>

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		<description><![CDATA[Solvency II, the EU directive that updates capital adequacy rules for the European insurance industry, is about to move to centre stage. We look at what IT departments of insurance companies in the UK must do. Compliance with Solvency II will provide IT &#8230; <a href="http://jeremywoolfe.be/2010/03/22/solvency-ii-what-cios-need-to-know/">Continue reading <span class="meta-nav">&#8594;</span></a>]]></description>
			<content:encoded><![CDATA[<p style="text-align: justify">Solvency II, the EU directive that           updates capital adequacy rules for the European insurance industry, is           about to move to centre stage. We look at what IT departments of insurance           companies in the UK must do.</p>
<p style="text-align: justify">Compliance with <a href="http://www.fsa.gov.uk/pages/About/What/International/solvency/index.shtml">Solvency II </a>will provide IT managers with many           challenges, not least the sheer scale of the exercise. There is also           greater complexity, with legal rules shifting from spelling out a           series of provisions, to being a principles-based system.</p>
<p style="text-align: justify">Peter Skinner, the British MEP who           nursed the package though the European Parliament, says,           &#8220;Solvency II shifts the focus of supervisory authorities from           merely checking compliance with a tick-the-box approach based on a set           of rules to more proactively supervising the risk management of           individual companies based on a set of principles.&#8221;</p>
<p style="text-align: justify">The directive, which cleared the           Brussels legislative machinery in April last year, requires IT           architectures to be ready for the directive&#8217;s enactment in national           legislation by 31 October 2012. Non-compliance could endanger an           insurance company&#8217;s right to trade.</p>
<p style="text-align: justify">Timing for setting up the modelling           software to meet of the new rules has to follow a set programme,           broken down into stages. For instance, according to risk management           consultancy Watson Wyatt, the UK Financial Services Authority (FSA)           required that as early as March 2009, firms should have stated whether           they plan to apply for internal model approval,</p>
<p style="text-align: justify">By June to November 2010, the start of           the first model dry-run period should have started. By October 2011,           the FSA should be in receipt of the first batch of dry-run           submissions. Second dry runs should take place in 2011 and 2012, with           the FSA review/approval process running from 2012.</p>
<p style="text-align: justify">Jürgen Weiss, principal research           analyst at Gartner, reckons that some companies will start the main IT           work in three months, but others will not get going for another nine           months.</p>
<p style="text-align: justify">Weiss says most European insurers are           still in &#8220;a discovery phase&#8221;. IT managers are uncertain           about budgeting their future Solvency II programmes. Some have not           even requested an IT budget to cover work in 2010 on the regulations.</p>
<p style="text-align: justify">Almost all IT organisations that are           familiar with the regulations have focused exclusively on the first of           the three pillars of Solvency II. This primarily addresses the           quantitative capital requirements for European insurers and the           actuarial models with which these requirements are being calculated.</p>
<p style="text-align: justify">Gartner believes the efforts to comply           with Pillar 2 requirements will be significantly higher than the           efforts for the other two Solvency pillar investments because of the           heterogeneous IT landscape of many insurers and the efforts to at           least semi-automate data collection and normalisation. Weiss says this           is worrying.</p>
<p style="text-align: justify">He says several level-two implementation           measures on Solvency II, published in November 2009 by the EU&#8217;s           advisory body for the insurance industry, the Committee of European           Insurance and Occupational Pensions (CEIOPS) explicitly address IT           issues. Examples are advice on data quality, data governance and           documentation.</p>
<p style="text-align: justify">Weiss says risk managers and actuaries           should now be collaborating with their IT colleagues. Business and IT           managers should also be aware that Solvency II requires a holistic           approach to risk management, encompassing people, processes and           applications.</p>
<p style="text-align: justify">A contrasting view on timing comes from           Steve Bell, financial services advisory partner at Ernst &amp; Young:           &#8220;With regard to timescales, there are a large number of interim           dates, and in my experience for most clients they are not running too           late as there is time remaining to gear up programmes.</p>
<p style="text-align: justify">&#8220;IT will need to deliver new or           enhanced risk management systems. This will be the key IT new system           build. The bigger challenge will be to provide accurate data to a           lower level of granularity on more regular intervals than before from           source systems many of which in insurance are legacy in nature. This           is the area that will be harder for insurance IT teams.&#8221;</p>
<p style="text-align: justify">Management consultancy Deloitte and           Touche is helping insurance companies to specify their IT needs to           enable them to purchase compliance software. It says an official EU           guideline, CP 58, gives a steer on the pre-application process,           offering &#8220;advice on supervisory reporting and disclosure deals           with the requirements for insurance companies to report to both the           regulators and the public&#8221;.</p>
<p style="text-align: justify">Companies lining up to supply insurance           companies with the software they need include: IBM, SAS, SAP, Oracle,           Sungard, Fermat, EMB, Algorithmics, Towers Perrin, plus a fragmented           array of specialist application providers.</p>
<p style="text-align: justify">IBM says the revision of its insurance           industry framework &#8211; which it describes as a blueprint to address all           three pillars of Solvency II &#8211; is complete and already being used by           more than 150 insurers.</p>
<p style="text-align: justify">Isabella Hess, senior managing           consultant at IBM Global Business Services, says IT departments should           be thinking about adopting an enterprise-wide information architecture           as, for most large groups, the concepts and strategic direction are           &#8220;more or less ready&#8221;.</p>
<p style="text-align: justify">Hess says there is little real choice as           the regulator and analysts are unlikely to look favourably on any big           player adopting a more simplistic, standard model-based risk           management framework.</p>
<p style="text-align: justify">One fundamental issue is the quality,           availability and traceability of data. For example, the data           &#8220;granularity&#8221; defined by data models is usually hardwired           into policy systems and can be difficult and expensive to change.           (Granularity is the level of detail of &#8220;attributes, &#8220;fields,           and data types that can be provided).</p>
<p style="text-align: justify">Similarly, insurers may need to collect           more comprehensive information about the quality and risk-sensitivity           of their investments portfolios than was required previously, and do           so more frequently and faster.</p>
<p style="text-align: justify">Solvency II software will eventually           better reflect an insurance company&#8217;s exposure to risk. This will           enable a company to plan its business development, liquidity           management and risk appetite to get the best payback on its capital           reserves. In other words, IT managers will be buying a system that           will enable firms to make better use of their capital.</p>
<p style="text-align: justify">Hess refers warmly to phase two of the           International Accounting Standard Board&#8217;s forthcoming IFRS 4 on           insurance contracts, for which an exposure draft is due in the second           quarter of 2010. In planning Solvency II architecture, she advocates           the use of other industry standards. These include Acord, the emerging           international standard for information exchange, and service-oriented           architecture for data exchange.</p>
<p style="text-align: justify">Hess says large insurance firms could be           facing bills for around €100m each as a result of Solvency II.           However, many have partially completed work on data and processes,           leaving only &#8220;heavy lift work in intellectual modelling and           embedding their enterprise risk models&#8221; to be done.</p>
<p style="text-align: justify">Hess estimates that second-tier insurers           will need to invest between €30m and €40m over three years.           Smaller companies could expect to pay €1m to &#8211; €1.5m each.</p>
<p style="text-align: justify">According to the CEA, the European           insurance and reinsurance federation, the total number of insurance           companies operating in the EU is 5,200. This figure could be increased           if one takes in associated economic zones, such as the European           Economic Community.</p>
<p style="text-align: justify">More accurate ideas on cost are likely           to come from the publication of the next Quantitative Impact           Studies (QIS) on Solvency II, expected in August 2010. The fifth           in a series of reports, the study aims to assess the likely impact on           insurance markets and products, social and economic impacts and the           likely impact on insurers&#8217; balance sheets and business behaviour of           the potential policy options being considered by the EC.</p>
<p style="text-align: justify">Insurance companies are reminded that in           2012 it will not be enough just to say that you have purchased a           Solvency II compliance software package. A Brussels mandarin close to           the directive emphasises that this will not satisfy the regulators.           &#8220;In the UK, the FSA will never give blind approval to the           software itself, but will check on functionality,&#8221; he says.</p>
<p style="text-align: justify"><a href="http://www.computerweekly.com/Home/"><img class="alignleft size-full wp-image-242" src="http://www.jeremywoolfe.be/wp/wp-content/uploads/2011/06/journa17.gif" alt="" width="282" height="48" /></a></p>
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		<title>Move afoot to store OTC derivatives data</title>
		<link>http://jeremywoolfe.be/2009/10/05/move-afoot-to-store-otc-derivatives-data/</link>
		<comments>http://jeremywoolfe.be/2009/10/05/move-afoot-to-store-otc-derivatives-data/#comments</comments>
		<pubDate>Mon, 05 Oct 2009 14:25:33 +0000</pubDate>
		<dc:creator>Fefaine</dc:creator>
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		<description><![CDATA[A central repository is among ideas on the EU table, says Jeremy Woolfe The European Union could follow the US in adopting the system of trade repositories for registering trades in credit default swaps. This move “could cast light on &#8230; <a href="http://jeremywoolfe.be/2009/10/05/move-afoot-to-store-otc-derivatives-data/">Continue reading <span class="meta-nav">&#8594;</span></a>]]></description>
			<content:encoded><![CDATA[<p>A central repository is among ideas on the EU table, says Jeremy             Woolfe</p>
<p>The             European Union could follow the US in adopting the system of trade             repositories for registering trades in credit default swaps. This             move “could cast light on over-the-counter markets in these             derivatives”, says Eddy Wymeersch, head of Cesr, the Paris-based             Committee of European Securities Regulators.</p>
<p>“The             set of the European version of the repository [data warehouse] and             the type of services provided will depend on the market             participants,” he adds.</p>
<p>Cesr,             which currently has an advisory role, is set to be upgraded under             plans announced by the European Commission. It will gain a new name,             becoming the European Securities and Markets Authority (Esma), and             binding powers as a senior financial regulator.</p>
<p>Mr             Wymeersch says a Cesr expert group has been studying the usefulness             of trade repositories to strengthen the post-trading infrastructure             of OTC derivatives, notably markets in credit default swaps, since             late last year. The initiative for the present study follows calls             by regulators in the EU for more public information about OTC             derivatives. EU finance ministers in December 2008 asked explicitly             for the risks to be looked into.</p>
<p>In             July, the European Commission adopted a communication that looks at             the role played by derivatives in the financial crisis. It seeks             steps to reduce risks, and ensure efficient, safe derivatives             markets.</p>
<p>Mr             Wymeersch says the Cesr investigation, <a title="[CESR] - Document" href="http://www.cesr.eu/popup2.php?id=6070" target="_blank">published as a consultation paper</a> last week,             aims to tackle the lack of transparency in the CDS market, which has             an estimated global notional gross value of about $30,000bn (£18,657bn,             €20,541bn).</p>
<div>
<p>Central banks and regulators are concerned about               the risks that may derive from this market, he says, referring to               the near collapse of AIG, which had</p>
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<blockquote><p>‘<em>Having information in one place is a crucial             contribution to reducing risk</em>’</p>
<p>Donald Donahue Chief executive, DTCC</p></blockquote>
<p>to             be propped up with $180bn of state support. To reduce risks,             initiatives have been supported to create central clearing houses.</p>
<p>The             central repository will come on top of this, says Mr Wymeersch,             functioning as a warehouse for the electronic storage of trades done             by dealers and others in OTC derivatives. It will create             transparency and reliability, and will allow banks to reconcile             their positions. It will also feed supervisors with much needed             detailed data about transactions and positions.</p>
<p>This             information will help both macro prudential supervision and micro             supervision, and perhaps avoid the accumulation of risk that was             known in the recent past. It would also provide supervisors mandated             to ensure market integrity with reliable data for investigating             market abuse cases.</p>
<p>As             for a third possible regulatory step, that is, bringing CDS trading             onto a regulated market, such as a stock exchange, Mr Wymeersch is             cautious. “This is a decision for market participants. If the US             will mandate this type of trading, Europe is likely to follow, to             avoid regulatory arbitrage,” he says.</p>
<p>In             a recent letter from Cesr to the European Commission, Mr Wymeersch             justifies the Cesr study on an EU repository by noting the large             number of European entities active in derivatives markets. He notes             the European origin of many underlying instruments, and the high             proportion of contracts denominated in euros.</p>
<p>Options             open to the Cesr expert group include doing nothing. But it could             also suggest setting up some kind of collaboration with the existing             trade repository for CDSs, the Trade Information Warehouse, although             sufficient guarantees for the European market operations would have             to be secured.</p>
<p>Set             up in 2006 by the Depository Trust &amp; Clearing Corporation in the             US, the warehouse holds transaction details on CDS contracts traded             by market participants in 35 countries. It played an important role             in bolstering the teetering financial system last year.</p>
<p>Last             October, after Lehman Brothers collapsed, the DTCC informed the             market that, based on its warehouse records, the exposure to             Lehman’s was a net notional value of about $6bn. This was done to             stem speculation that the credit derivative exposure was $400bn.             When the Lehman exposure was closed out, the actual value was             $5.2bn.</p>
<p>Given             the complexity of CDS contracts, “having all of this information             residing in a single place is a crucial contribution to reducing             risk and promoting market efficiency”, says Donald Donahue, DTCC             chairman and chief executive.</p>
<p>Cesr             itself takes a neutral stand as to who should be in charge of             organising a European trade repository, says Mr Wymeersch.             “However, it [Cesr] will lay down rules to ensure safety and             efficiency. Such rules will cover open access to any proposal for a             repository.”</p>
<p>He             adds: “European operators may come forward with proposals.”</p>
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