Changes from the June version include;
- Introductory paragraph added on ensuring that continuity and development of long-term guaranteed business is not impaired when developing this text.
- EIOPA now obliged to produce technical information on the Equity Risk sub-module of standard formula
- Supervisors will be applying laws and regs required to comply with implementation plan requirements from 1st April 2013 (this was from 30th June)
- Guidance from EIOPA on what the “implementation plan” requirements are still expected on 31st March 2013 – must now also contain guidance in the context of proportionality.
- The implementation plan must specify which, if any, transitional measures will be utilised.
Most significant one seems to be the third one – I can’t fathom why they have expressly said that regulators need to be able to police the implementation plans in April 2013, if they are not due to be submitted until June 2013.
It may be that the national regulators have lobbied to be able to check up on companies pre-submission to make sure the implementation plans are compiled to their liking first time round. With little room for latency, I suppose that would make sense.