DNB and APG have both written a position paper as a contribution to the expert meeting for the Senate. The findings including the reports can be found below.
DNB:
It is mainly a formal support of DNB for the new pension system. Attention is drawn to good preparation, reducing complexity as much as possible and tackling the transition as a joint project of all stakeholders. The AFM and DNB will set up a platform for the pension transition in order to gain insight into and address transition bottlenecks in a timely manner. DNB is working on guidance on how DNB interprets the new laws and regulations and how DNB will supervise them.
The link to the position paper can be found here.
APG:
APG has written a positioning paper as a contribution to the expert meeting for the Senate as well. APG is putting forward an issue that according to AF Advisors is a major concern. To be prepared in time, pension funds and administrators are already working out the details of the new pension system including the operational set-up. But legislation on a lower level as well as policy guidelines are still not available. Therefore the legislation that is available is being interpreted based on working hypothesis and assumptions. Implementation risks are increasing if clarity is not provided in time which leads to postponed final decision making. This may lead to decreasing possibilities to spread the implementation and transition to the new system which in turn leads to other problems such as the availability of scarce resources to manage the transition. An important aspect to raise at this point in time.
The link to the position paper can be found here.
