Insurance Europe welcomes EIOPA's opportunity to provide feedback on its draft Opinion on supervising the liquidity risk management of IORPs. While agreeing with the overarching objective, the industry believes that existing regulatory frameworks already adequately address the sources of liquidity risks identified in the consultation paper.
A key consideration for Insurance Europe is the need for a proportionate approach to liquidity risk management. Such an approach should be tailored to the specific risk profile of each IORP, recognising the diverse nature of these institutions.
Furthermore, in its response, Insurance Europe disagrees with some of the specific proposals outlined in the draft Opinion. For example, the requirement for IORPs to establish a new, specific liquidity risk tolerance level is unnecessary.