Summary Of Comments On Consultation Paper 63 - Europa
Summary of Comments on Consultation Paper 63 - CEIOPS-CP63/09CEIOPS-SEC-165-09CP No. 63 - L2 Advice on Repackaged Loans InvestmentCEIOPS would like to thank Association of German Pfandbrief Banks (vdp), CEAECO-SLV-09-620, CRO Forum, Deloitte European Union member firms of Deloitte T, DIMA (Dublin International Insurance & Management, European Insurance CFO Forum, FFSA, GDV (German Insurance Association), GROUPAMA, Groupe Consultatif, IUA, Legal & GeneralGroup, Lloyd’s, Lucida plc, Munich Re, RBS Insurance, RSA Insurance Group, and XL Capital LtdThe numbering of the paragraphs refers to Consultation Paper No. 63 alCommentThe CEA welcomes the opportunity to comment on theConsultation Paper (CP) No. 63 on Repackaged loans investment.ECO-SLV09-620ResolutionNoted.It should be noted that the comments in this document should beconsidered in the context of other publications by the CEA.Also, the comments in this document should be considered as awhole, i.e. they constitute a coherent package and as such, therejection of elements of our positions may affect the remainder ofour comments.These are CEA’s views at the current stage of the project. As ourwork develops, these views may evolve depending in particular,on other elements of the framework which are not yet fixed.1.Moreover, it should be noted that this consultation hasbeen carried on an extremely short time frame which has notResolutions on Comments on CEIOPS-CP-63/09 (L2 Advice on Repackaged Loans Investment)1/98Noted.
Summary of Comments on Consultation Paper 63 - CEIOPS-CP63/09CEIOPS-SEC-165-09CP No. 63 - L2 Advice on Repackaged Loans Investmentallowed a complete analysis of all the advice. Therefore, thefollowing comments focus only on the main aspects of Ceiops’advice and are likely to be subject to further elaboration in thefuture.The CEA is generally in favour of the principles based approach ofthe consultation paper and of cross-sectoral consistency, subjectto it achieving appropriate insurance regulations. In this instancethe CEA supports cross-sectoral consistency providedproportionality is applied and that appropriate account is taken ofthe much lower exposure in terms of the amount and the qualityof investments in such products taken by the insurance sectorcompared to the banking sector.2.We believe that the investment in such repackaged loaninvestments should be mainly guided by the prudent personprinciple stated by the Directive.3.These investments are an important component of thecurrent economy, and the present restrictions/rules couldseverely limit the asset management of insurance company.Further, CP63 has to be regarded in connection with CPs 69, 70and 74. We believe that the effect of tougher capitalrequirements, in connection with additional qualitativerequirements for investments in repackaged loans, is harmful forthe construction of a diversified portfolio. From our perspective,the entirety of new requirements directed towards investmentswill most certainly have a significant effect on the possibilities forinsurance companies to take on market risk. The asset allocationwill undoubtedly be pushed away from a diversified portfolioResolutions on Comments on CEIOPS-CP-63/09 (L2 Advice on Repackaged Loans Investment)2/98The principle of proportionality isan overarching concept underSolvency II and therefore appliesthroughout CP63, as to all otherCEIOPS’ publications. Aparagraph on the principle ofproportionality has beenspecifically added to the paper inorder to highlight this fact at theoutset of the paper.Under the prudent personprinciple (Article 132 in the Level1 Directive), if undertakingsconsider that they are unable toproperly identify, measure,monitor, manage, control andreport the risks applicable totradable securities and otherfinancial instruments based onrepackaged loans then theyshould be making the decision tonot invest in these products in
Summary of Comments on Consultation Paper 63 - CEIOPS-CP63/09CEIOPS-SEC-165-09CP No. 63 - L2 Advice on Repackaged Loans Investmentstructure towards a concentration on certain low yield products, inparticular government bonds. For these reason, we firmlydisagree with any restriction on investments, which is consideredto be a direct intervention of the supervisor in the management ofthe undertaking.the first place. This assessmentshould be made in advance ofany investment decision; notjust when investing in tradablesecurities and other financialinstruments based onrepackaged loans. This papersets out requirements CEIOPSwould expect to see specificallyfor repackaged loans and itshould therefore not be viewedas a restriction but a safeguardthat recognises the risk thatexists within these products. Therequirements do not preventundertakings from investing insuch instruments as long as therequirements are met.The Level 1 Directive states thatAs they are proposed now, the requirements to be met bycross-sectoral consistency shouldundertakings investing in repackaged loans are heavy and difficultbe maintained to ensure a levelto apply in practice.playing field between those firmsWhile we recognize the need to check the 5% retention and tosubject to Solvency 2 and thoseperform a proper assessment of the originator and sponsor atsubject to the CRD. CEIOPS haspurchase, we strongly believe that undertakings cannot befollowed this approach as closelyexpected to monitor how these requirements are fulfilled on aas possible within the scope ofcontinuous basis. Instead, the CEA expects that the retention ofthe Solvency II Directive andthis minimum economic interest and other requirements listedintends to continue doing so asunder the other originator related principles are checked by theand when policy developments incompetent regulators. Insurance undertakings should be able tothe CRD dictate. In relation toResolutions on Comments on CEIOPS-CP-63/09 (L2 Advice on Repackaged Loans Investment)3/98
Summary of Comments on Consultation Paper 63 - CEIOPS-CP63/09CEIOPS-SEC-165-09CP No. 63 - L2 Advice on Repackaged Loans Investmenttake credit for the activity of these regulators and not beexpected to duplicate their role.It is also not clear what happens to these investments inrepackaged loans when the listed requirements, especially fororiginators, cease to be fulfilled. A binary yes/no recognition ofsuch investments could lead to distressed sales, even in caseswhere the breach is minor. The CEA proposes instead that anybreaches of the requirements listed in this paper are assessed byundertakings and supervisors on case by case basis, as part ofthe Pillar II review.Resolutions on Comments on CEIOPS-CP-63/09 (L2 Advice on Repackaged Loans Investment)4/98ensuring originators’ compliancewith the requirements,originators may not necessarilybe CRD-regulated entities and –even to the extent that they maybe – undertakings should remainresponsible for monitoring as itis their decision to invest in thefirst place. The paperemphasises that it should not be- and is not - the responsibilityof the regulatory authority tocarry out this task. A paragraphin the paper acknowledges thispoint.CEIOPS has added a section onthis subject to the paper;outlining two situations in whichit considers that breaches of therequirements would haveoccurred (both in relation to theoriginator and the investorfailing to fulfil their obligations)and the consequences shouldsuch breaches occur.Information has also been addedon the consequences of anoriginator failing to comply withthe requirements after the
Summary of Comments on Consultation Paper 63 - CEIOPS-CP63/09CEIOPS-SEC-165-09CP No. 63 - L2 Advice on Repackaged Loans Investmentinvestment has been made.The proposed grandfathering arrangements may lead to forcedsales of repackaged loan assets. Indeed, the proposal thatgrandfathering should cease to apply for repackaged loaninvestments where new underlying exposures are added orsubstituted is too onerous and unworkable in practice. Inparticular, substitutions of the underlying exposures with a viewto keep or increase the credit quality of the investment is in linewith good risk management practices and therefore should not bedis-incentivised.The definition of repackaged loans or similar financialarrangements should be specified. The definition should be inaccordance to the CRD. Hence, we request Ceiops to specify thatCP63 deals with securitisations in the sense of the definition ofResolutions on Comments on CEIOPS-CP-63/09 (L2 Advice on Repackaged Loans Investment)5/98CEIOPS has re-drafted thegrandfathering section in thepaper in a bid to ensure clarity ofthe requirements and hasoutlined four possible scenariosto consider for this purpose. Inorder to maintain consistencywith the banking sector, CEIOPSproposes to adopt an approachto substitutions of and /oradditions to the underlyingexposures comparable with thatstated in the CRD; substitutionsand additions can still be madeand may not be subject toSolvency II rules, depending onconditions being met on themateriality of and the intentionbehind such an addition and/orsubstitution being made.Information has been added tothe paper in this regard.CEIOPS has clarified thedefinition of ‘repackaged loans’in the paper (with references inthe paper having been changed
Summary of Comments on Consultation Paper 63 - CEIOPS-CP63/09CEIOPS-SEC-165-09CP No. 63 - L2 Advice on Repackaged Loans Investment2.CRO ForumGeneralCommentthe Basel II Accord.to “tradable securities and otherfinancial instruments based onrepackaged loans”). Thedefinitions included in the CRDhave been adopted. Furtherinformation has been added onthe scope of the paper in termsof the type of financialinstrument to which therequirements would apply (withreferences to specific types offinancial instrument beingremoved from the scope sectionof the paper). Ensuring crosssectoral consistency with thebanking sector is a mainobjective of the paper and – tothis extent – CEIOPS proposes touse the lists and definitionscontained within the CRD as theyapply to this advice (in terms ofexemptions, for example).1.63.A There is need for an appropriate balance betweencontrolling risk, ensuring practicability for issuers of theseproducts and also respecting the principle of “freedom ofinvestment” (priority: medium)Noted.2.The advice in this paper should be balanced between 2important Principles in the Directive: “Prudent Person” (Art 132)and also “Freedom of Investment” (Art 133). This article statesthat “Member States shall not subject the investment decisions ofan insurance or reinsurance undertaking or its investmentSee previous response (1) onthe prudent person principle.Resolutions on Comments on CEIOPS-CP-63/09 (L2 Advice on Repackaged Loans Investment)6/98
Summary of Comments on Consultation Paper 63 - CEIOPS-CP63/09CEIOPS-SEC-165-09CP No. 63 - L2 Advice on Repackaged Loans Investmentmanager to any kind of prior approval or systematic notificationrequirements.”3.The CRO Forum expects that all undertakings will maintainadequate risk management systems including the ability tomonitor and analyse assets. The general requirements underSolvency II provide a sufficient basis to control investmentwithout special measures.4.If measures are deemed necessary they should be in theform of principles to guide good practice not restrictions oninvestment. They will need to find an appropriate balancebetween controlling risk, being practicable for issuers of productsbased on repackaged loans while ensuring sufficient but notexcessive disclosure and transparency to the investors who needto understand what they are buying.Noted.See previous response (1) onthe prudent person principle.See previous response (1) on5.In addition, the CRO Forum would expect insurance linkedthe definitions contained withinsecurities to be covered by the general risk management andthe paper and the scope of theinvestment principles of the Directive and not by these measures.requirements.If they are in scope some significant adjustments would beneeded, for example to deal flexibly with the full range of possiblenon indemnity triggers.6.63.B CROF supports CEIOPS use of a principles basedapproach (priority: medium)Noted.7.We consider the principles proposed by CEIOPS as a goodframe of reference to keep in mind when investing in such assets. Noted.8.This principle based approach will allow flexibility in anarea where further developments are to be expected. However,we note:that when adapting the measures developed by CEBS,CEIOPS should ensure proper consultation of the industry and theResolutions on Comments on CEIOPS-CP-63/09 (L2 Advice on Repackaged Loans Investment)7/98Noted.
Summary of Comments on Consultation Paper 63 - CEIOPS-CP63/09CEIOPS-SEC-165-09CP No. 63 - L2 Advice on Repackaged Loans Investmenttreatment for insurers as investors is the consistent with that forbanksthat there will need to be clarity on what constitutes aneligible arrangement both when issued by CRD controlled entitiesand by others. Unanticipated disallowance is a risk created by theregime and insurers will need it to be minimized.that the requirement for originator to retain an interest ofa least 5% is a sound principle but application needs to allow forpractical issues and for managing the exposure.CROF’s interpretation of the paper is that if an existingSee previous response (1) oninvestment no longer complies with the principles thetypes of breaches and(re)insurance undertaking will be required to close their position.consequences of such breaches.Such a requirement risks amplifying pro-cyclicality effects. Wepropose that where monitoring is not considered sufficientlydiligent, a transition period should be allowed for enhancement ofprocedures up to the required standard. This is especiallyimportant given the potential for differing views as to whatconstitutes an acceptable level of due diligence. There should bea window, assessed on a case-by-cased basis with the supervisor,to make disposals to ensure there are no pro-cyclical effectsthrough forced sales.9.63.C Recognition of Grandfathering in Level2 is welcomebut some clarification is required (priority: high)10.We would like to highlight that securitised products, suchas collateralised debt obligations (“CDO”s), actively manage theunderlying credit exposure to ensure that credit quality ismaintained through additions and substitutions to the existingsecuritisation. Therefore such a requirement imposed onResolutions on Comments on CEIOPS-CP-63/09 (L2 Advice on Repackaged Loans Investment)8/98See previous response (1) onthe extension of thegrandfathering section in thepaper. As previously noted,substitutions are not beingbanned but rather are being
Summary of Comments on Consultation Paper 63 - CEIOPS-CP63/09CEIOPS-SEC-165-09CP No. 63 - L2 Advice on Repackaged Loans Investmentoriginators is unreasonable and could effectively render thegrandfathering useless.11.We strongly recommend CEIOPS to clarify that thechanges in the exposure that would revoke the grandfatheringapplies to the addition/ substitutions of the assets by theholders/investors of the securitised loans and not the alInsurance &Management4.EuropeanInsuranceCFO ForumGeneralCommentDIMA welcomes the opportunity to comment on this paper.brought under the scope ofSolvency II, with specificexceptions.Noted.Comments on this paper may not necessarily have been made inconjunction with other consultation papers issued by CEIOPS.DIMA welcomes the principled-based approach being taken andthe aim of cross-sectoral consistency. However, the restrictionfrom investing in certain assets where either the asset or theundertaking fails to meet some criteria is unnecessary andunprecedented. The simple expedient of valuing such assets at nilshould be sufficient, given that no further downside valuation riskcould arise thereafter.See previous response (1) oncross-sectoral consistency.There is some concern that the approach as indicated in thispaper could results in re/insurers eliminating this asset sectoraltogether. It is unclear whether pre-trade compliance would besufficient to ensure the 5% holding is maintained by theoriginator.See previous response (1) ontypes of breaches and theconsequences of such breaches.It is inconsistent with the principles of Solvency II to prohibitundertakings in terms of the nature of the investments they canhold.See previous response (1) onthe prudent person principle.The CFO Forum recognises the Level 1 Directive requirements foradvice to be drafted but is of the opinion that this proposal is notconsistent with the underlying principles of Solvency II that implyResolutions on Comments on CEIOPS-CP-63/09 (L2 Advice on Repackaged Loans Investment)9/98See previous response (1) onthe prudent person principle.
Summary of Comments on Consultation Paper 63 - CEIOPS-CP63/09CEIOPS-SEC-165-09CP No. 63 - L2 Advice on Repackaged Loans Investmentthat insurers are permitted to invest as they wish subject to thenormal Solvency II constraints. Solvency II should not prohibitundertakings in terms of the nature of the investments they canhold. Solvency II principles require insurers to understand theirrisks and hold appropriate capital rather than explicitly restrictinginvestment activities.It is inappropriate for the supervisor to prohibit investmentsunless specific conditions are met. The conditions should be moreprinciple-based and any “penalty” should involve the requiredcapital measurement for solvency purposes. Also, we emphasisethat there must remain degrees of freedom for undertakings andtheir asset managers to take investment decisions undermaintainable effort.See previous responses (1) onthe prudent person principle andthe consequences ofrequirements being breached.The requirement for the originator to meet the investment criteria Noted.could be problematic for undertakings investing in non-EUregulated territories.We recognise that this is Level 1 text but highlight that therequirements could be problematic for subsidiaries doing businessin non-EU jurisdictions in which there might not be enoughmarket pressure to force third parties to change their businessmodel to conform to EU rules. This would restrict investmentopportunity, which is not consistent with the underlying principlesof Solvency II.CP63 could create a competitive disadvantage for Europeaninsurers needing to make non-European investments.For European investments, CP63 advice may have a reducedimpact on new investments as it is assumed that the CRD willResolutions on Comments on CEIOPS-CP-63/09 (L2 Advice on Repackaged Loans Investment)10/98Regardless of whether theoriginator is a third countryentity or not, undertakingsshould be investing according tothe principles outlined in thepaper in order to allow theproper identification,measurement, monitoring,management, control andreporting of the risks associatedwith their investment portfolios.Third country originators
Summary of Comments on Consultation Paper 63 - CEIOPS-CP63/09CEIOPS-SEC-165-09CP No. 63 - L2 Advice on Repackaged Loans Investmentrequire originators to apply the stated principle. It will, however,impact European insurers needing to make non-Europeaninvestments. CP63 restricts undertakings on investments inmarkets outside of Europe which are not governed by the CRD.This could, for example, create a competitive disadvantage for thenon-European operations of European Groups.securitising ‘good’ risks shouldnot be averse to holding aretained interest or, indeed,from being transparent in theirbusiness when selling on suchfinancial instruments. Given thesize of the European market andthe business available therein, alarge incentive therefore existsfor third country originators toself-select into the group ofcountries that are compliant withthe requirements outlined underthe CRD and Solvency II.It would practically be very difficult and potentially very costly toensure that originators are continuing to retain at least 5% of allrepackaged loan investments.See previous response (1) onthe prudent person principle. Ifthe necessary level of dueThere will be issues with the practicalities of managing exposures. diligence makes the decision toIt is not clear whether an undertaking could place reliance on ainvest an uneconomical one,credit agency or the fact that an originator has guaranteed thatundertakings may choose not tothey will retain 5% of the interest, without further verification.invest.The CFO Forum opposes a forced fire-sale of securities if theoriginator no longer complies with the principles set out in theconsultation paper. It would be preferable to say thatundertakings should have a robust policy for monitoringexposures and assessing the overall risk of these investments.The requirement for investors to look through to the underlyingexposures will be very onerous.Resolutions on Comments on CEIOPS-CP-63/09 (L2 Advice on Repackaged Loans Investment)11/98See previous response (1) ontypes of breaches andconsequences of such breaches.See previous response (1) on
Summary of Comments on Consultation Paper 63 - CEIOPS-CP63/09CEIOPS-SEC-165-09CP No. 63 - L2 Advice on Repackaged Loans InvestmentThe consultation paper requires investors to look through to theunderlying exposures. If the original loan is subsequentlyrepackaged, it will be very onerous for companies to look throughto the original exposures. This should be the responsibility of theregulator of the originator rather than the responsibility of theinvestor.With respect to grandfathering, substitutions within the originalterms of the investment should not be regarded as a change tothat investment and pre-existing rules should continue to apply.the responsibilities ofundertakings in checkingoriginator’s compliance with therequirements.See previous response (1) onthe grandfathering provision.Substitutions can occur when there is a requirement to replace adefaulted exposure with one that has not defaulted. In thisscenario, it is counter to good risk management practices todiscourage substitutions.5.FFSAGeneralCommentIt should be noted that the CP is based on current draft CRD.Final advice and level 2 measures should be adapted to futureevolution of the CRD.Covered bonds should be explicitly excluded from the repackagedloans. Indeed, an investor is exposed to the issuer for this kind ofinvestments, and not directly to a pool of assets. A contrario, thepool of assets is a collateral against any insolvency of the issuer,and provides more security to the investor. We understand thatthe CRD could be amended to exclude these investments. Weconsider that this exclusion shall be made within level 2implementation measure of the Directive.Noted.See previous response (1) onthe clarification of the scope ofthe paper. CEIOPS does notbelieve that covered bondswould be subject to therequirements.The CP requires undertakings to have access to lots of informationSee previous responses (1) onand documentation provided by originators and sponsors, to becross-sectoral consistency andResolutions on Comments on CEIOPS-CP-63/09 (L2 Advice on Repackaged Loans Investment)12/98
Summary of Comments on Consultation Paper 63 - CEIOPS-CP63/09CEIOPS-SEC-165-09CP No. 63 - L2 Advice on Repackaged Loans Investmentable to perform stress tests on underlying assets and challengeassumptions of rating agencies, to be fully skilled in theseinvestments, which should put them off investing in complexrepackaged loans. Some of these obligations are not feasible forinsurance companies (such as principles 2, 4 and 6).the prudent person principle.These investments are an important component of the currenteconomy, and the present restrictions/rules could severely limitthe asset management of insurance company. Furthermore, creditinstitutions do not have any prohibition from investing in suchassets if they do not respect the CRD criteria; in this case, theircapital charge is simply higher. For that reason, we firmlydisagree with any restriction on investments, which is consideredto be a direct intervention of the supervisor in the management ofthe undertaking. In case the company does not comply with theprinciples, we would suggest that the relating investments arededucted from the own funds of the undertaking.There are not typically largeexposures of these instrumentsin insurance companies.Therefore, CEIOPS is notconvinced that the requirementsoutlined in the paper couldseverely limit asset management(see footnote no. 2 in the finaladvice).Also, if at inception, when the undertaking invests in one loanrepackaged, it complies with the principles, and that during thelife of the investment, one of the principle is breached, in thiscase, the undertaking should not have to sell the repackagedloan. Instead, we would propose to deduct the fair value of theSee previous response (1) onbreaches of requirements andconsequences of such breaches.Resolutions on Comments on CEIOPS-CP-63/09 (L2 Advice on Repackaged Loans Investment)13/98See previous responses (1) onthe prudent person principle andbreaches of the requirementsand consequences of suchbreaches.With regard to capital charges,the SCR is not set to adequatelyreflect such an arrangement.CEIOPS must follow Level 1 inrelation to this but will seek toexplore this further at Level 3.
Summary of Comments on Consultation Paper 63 - CEIOPS-CP63/09CEIOPS-SEC-165-09CP No. 63 - L2 Advice on Repackaged Loans Investmentrelated investment from the own funds.The CP essentially refers to Basel II principles which are level 1measures (directive level). Solvency II Implementing measuresshould be more precise and more related to insurance issues,despite the necessary cross-sectoral consistency.The CP indicates in principle 2 that the undertaking has tomonitor the sponsor and credit institutions. We consider that ifthese financial institutions are regulated, under Basel II, theundertaking has not to ensure that sponsor and originator creditinstitutions meet the criteria presented in principle 2.Also, in principle 6, the CP indicates one cannot rely on the ratingprovided by the external rating agencies. Since this industry willbe regulated, we consider this approach is not reasonable, andthe ratings should be considered as reliable.Finally, the CP is mentioning the grandfathering rule, withoutResolutions on Comments on CEIOPS-CP-63/09 (L2 Advice on Repackaged Loans Investment)14/98Noted.See previous response (1) oncross-sectoral consistency.The paper states thatundertakings should not placesole reliance on an ExternalCredit Assessment Institution(ECAI) assessment; the purposeof these models may notnecessarily be aligned with theneeds of the undertaking.However, undertakings maychoose to consider such ratingsas part of a wider and morecomprehensive assessment ofthe investment decision. This isconsistent with the approachtaken under the CRD.See previous response (1) onthe grandfathering principle.
Summary of Comments on Consultation Paper 63 - CEIOPS-CP63/09CP No. 63 - L2 Advice on Repackaged Loans Investmentindicating what will happen if the existing securitisations wouldnot meet the requirements after a restructuration. We remindthat the undertaking cannot decide on the restructuring orsubstitution of underlyings within these investments. Werecommend that the relating investments are charged with thestandard risk module until its life tGDV recognises CEIOPS’ effort regarding the implementingNoted.measures and likes to comment on this consultation paper. Ingeneral, GDV supports the detailed comment of CEA.Nevertheless, the GDV highlights the most important issues forthe German market based on CEIOPS’ advice in the blue boxes. Itshould be noted that our comments might change as our workdevelops.Based on our experience during the previous two consultationwaves we also want to express our concerns with regard toCEIOPS decisions:1.restricting the consultation period of the 3rd wave to lessthan 6 six weeks2.splitting the advice to the EU-commission in two parts ((1)first second wave and (2) third wave) although both parts arehighly interdependent3.not taking into account many comments from the industrydue to the high time pressure (first second wave)Resolutions on Comments on CEIOPS-CP-63/09 (L2 Advice on Repackaged Loans Investment)15/98Noted.CEIOPS-SEC-165-09
Summary of Comments on Consultation Paper 63 - CEIOPS-CP63/09CEIOPS-SEC-165-09CP No. 63 - L2 Advice on Repackaged Loans InvestmentThese decisions could reduce the quality of the outcome of thisconsultation process. Therefore we might deliver furthercomments after we fully reviewed the documents.From our point of view, it could be foreseen that especially thecalibration of the QIS5 will not be appropriate nor finalised whenbeginning in August 2010.The asset allocation will undoubtedly be pushed away form adiversified portfolioNoted.Noted.This paper is only addressingone specific type of product. InCEIOPS’ view, a diversifiedportfolio is still possible.See previous response (1) onCP63 has to be regarded in connection with CPs 69, 70 and 74.the prudent person principle andWe believe that the effects of tougher capital requirements inan undertaking’s assessment ofconnection with additional qualitative requirements forits investment decision.investments in securitisations are harmful for the construction ofa diversified portfolio. From our perspective, the entirety of newrequirements directed towards investments will most certainlyhave a significant effect on the possibilities for insurancecompanies to take on market risk. The asset allocation willundoubtedly be pushed away form a diversified portfolio structuretowards a concentration on certain low yield products, inparticular government bonds.The GDV is generally in favour of the principles based approach of See previous response (1) onthe principl
The numbering of the paragraphs refers to Consultation Paper No. 63 (CEIOPS-CP-63/09) No. Name Reference Comment Resolution 1. CEA ECO-SLV-09-620 General Comment The CEA welcomes the opportunity to comment on the Consultation Paper (CP) No. 63 on Repackaged loans investment. It should be noted that the comments in this document should be
This Consultation Paper, Measurement, was developed and approved by the International Public Sector Accounting Standards Board (IPSASB ). The proposals in this Consultation Paper may be modified in light of comments received before being issued in final form. Comments are requested by September 30, 2019. Respondents are asked to submit their comments electronically through the IPSASB .
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The results of the consultation activities will be summarised in a synopsis report annexed to the impact assessment and published on the consultation page. 5. Summary /overview on consultation activities by stakeholder groups and indicative timing The following table summarises the envisaged consultation activities, their stakeholder coverage and
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