Impact assessment on the reporting package for Solvency II
EIOPA har lämnat förslag på rapporteringsmallar i det kommande regelverket Solvens II. Fondbolagens Förening har lämnat förljande synpunkter:
CP 009/2011: Impact assessment on the reporting package for Solvency II
The Swedish Investment Fund Association has two general remarks. First it is not necessary or reasonable to stretch the reporting requirements to cover funds where the insurance company owns the fund but the policyholders bears the risk in the fund. This is not a risk for the insurance company. Secondly, if those assets must be included in the reporting the reporting requirements are too detailed. Given this level of details the providers of these funds must provide specific information to the insurance companies. Moreover, these funds are already covered by legislation, both from the UCTIS-directive and from the MiFID-directive, and more legislation is to come from the AIFM-directive. They already report according to these directives, and that reporting ought to be sufficient. The risk if these reporting requirements are put on the suppliers of funds is that fewer funds could be offered to policyholders, for small players it could be too burdensome if they have to provide information to the insurance companies in a specific Solvency II-way. Thereby the risk is that there will be a concentration of the suppliers and only suppliers that are Solvency II-compliant will be used for unit-link insurance. In addition the increased reporting requirements will lead to administrative costs, both for the insurance company and the fund suppliers and the costs will be charged to customers, ie, an increased cost to consumers.
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