According to the Pensioenfederatie, De Nederlandsche Bank (DNB) has been dubbed over-inquisitive for asking pension funds the documentation they need to provide if they plan to make the transition to the Dutch new defined contribution (DC) system.
The regulator’s attitude risks further delaying the pension transition.
In a 44-page rebuke of a set of regulatory documents in which pension regulator DNB outlays its policy plans for the pension transition, the Pensioenfederatie said DNB is often asking for too many documents, overburdening pension funds in the process.
“With an eye on the regulatory pressure, DNB should not ask for more argumentation than strictly necessary according to the law,” said Pensioenfederatie director Edith Maat.
DNB is also asking for “extreme” amounts of calculations on how certain scenarios would impact different groups of members which is not even required by law, according to the pension fund organisation.
“For example, for the analysis of the costs and benefits of the solidary or risk sharing buffer a qualitative analysis would suffice instead of a quantitative analysis as asked by DNB,” the Pensioenfederatie wrote in its consultation response, warning DNB’s excessive demands risk delaying the pension transition further.
Discretionary power
The Pensioenfederatie is also unhappy that DNB wants to give itself excessive discretionary power to block the transition of pension funds to the new DC system.
According to a Q&A document, DNB can block a pension fund’s decision to make the transition to DC “if it can be stated that (a part of) the fund’s members, former members, other people entitled to benefits, pensioners may not feel represented in a balanced way”.
“This is far too broad a formulation which is not desirable,” said the Pensioenfederatie, which added that a lot of it is “unnecessarily subjective”.
The Pensioenfederatie also believes DNB grants itself too much time to respond to a pension fund’s request to make the transition to the new system: six months, plus the possibility of two three-month extensions.
The Pensioenfederatie wants DNB to confirm it will in principle not take more than six months to evaluate a request and that it can only take more time in exceptional circumstances, based on clear criteria.
This article appeared originally in Pensioen Pro, IPE’s Dutch sister publication.
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