|Omnibus II draftsmen - you're free to go|
- An enormous amount of preamble to factor in EIOPA's new role, which gets more elaborate with every paragraph,
- References to IAIS developments for future considerations on the equivalence front (will that be enough to cover the States and Canada long-term?)
- Some hard coding of references to "20% of market" for exemptions from reporting requirements,
- Visibility of the drop dates being proposed for EIOPA to deliver implementing and regulatory technical standards to the Commission - a reasonable amount are due in less than a year, including on model approval and "major" model changes.
As EIOPA will be penning all technical standards for the Commission, and relations between the two seemingly cordial, we might assume that EIOPA's views (which were almost immovable during the consultation on their preparatory guidance) will inevitably come to the fore in the final set of implementing measures.
Whatever comes of it, it would appear that the trilogue negotiations haven't quite done the job for the German contingent, with Hr. Hufeld from BaFin suggesting there are "5 to 10" insurers under his watch in danger of failure, a week after the German Government referred to a "balanced package" of help for their (seemingly) beleaguered industry which will be introduced in early 2014.
"Das Gleichgewicht wird zum Verlust..."