European Policy Analysis Volume 2, Number 1, Spring 2016 | Page 53

European Policy Analysis

been clearer, with 79% of respondents
favoring DC PPPs and only 7% for DB
(with the remainder of comments calling
for a balanced approach). Yet, EIOPA’s
own Occupational Pensions Stakeholder
Groups pointed out that the DB-DC
dichotomy is incapable of absorbing
a key distinction between products,
namely “who is going to bear what risk?”
(EIOPA 2014a, com. 63). It then goes on
to propose to classify PPPs according to
the distribution of “three main classes of
risks: financial risks, mortality/survival
risks,
and
expenses/administration
risks.” Insurance-based PPPs often cover
substantial parts of the second and,
therefore, have distinguishable actuarial
characteristics as well as particular costbenefit profiles to customers, both of
which differ between national member
state contexts.23 The Slovak Insurance
Association, for instance, highlights
its opposition to a Europeanization of
mortality tables (EIOPA 2014a, gen. com.
26). Consequently, it proposes that EIOPA
should promote reinforced 3rd pillar
investment, but asks it to refrain from
marketing of a standardized product.24
This relates to the question raised by
the Luxembourg-based Association of
International Life Offices (in EIOPA
2014a, com. 323, formally an answer to

a taxation question) what actually is to
be counted as a pension in the emerging
European regulatory regime. Insurancebased products significantly differ both
from other PPPs and between themselves.
An example for the latter within variation
is the high frequency of lump-sum payoffs
in some markets such as Germany and
their prohibition in others like the United
Kingdom (EIOPA 2014a, com. 323).

An additional type of answer to
the aforementioned Question 2 (voiced in
EIOPA 2014a, com. 53, 56, 68, and 71 as
well as gen. com. 12—all stemming from
stakeholders with a strong base in the 2nd
pillar) negates the need for any regulatory
initiative by EIOPA, based on the view
that national regulatory agencies are fully
(and/or more) capable of dealing with
current concerns. Detailed regulation of
numerous aspects beyond the definition
of a more or less standardized product,
on the other hand, is lobbied for only by a
very small minority of stakeholders. This
picture ties in directly with the answers
to Question 3, where EIOPA inquired
whether stakeholders perceive the need
for additional prudential requirements,
and a little more than 50% of the
comments offered see no such necessity.
About a quarter of comments to Question
3 raise fairly minor technical questions

23

Linked to the financial risks first mentioned is the question of capital or interest guarantees below
the threshold of full DB. There is also national regulatory variation as of now, and a potential area for
EIOPA activities according to some stakeholders (cf., e.g., EIOPA 2014a, gen. com. 9 and com. 54).
24
A position taken even more vehemently by the EIOPA Occupational Pensions Stakeholder Group: “It
is not the task of the COM nor the Authority to support or promote direct or indirect EU-wide future
product marketing campaigns […] which might have the effect of undermining the extension of highly
efficient occupational pension concepts in the MS” (EIOPA 2014a, gen. com. 11; also see Topic 3 in this
regard).

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