Part 2 of an extensive interview with Carlos Montalvo, Executive Director of EIOPA, in which he discusses the EIOPA Guidelines and the challenges of preparing for Solvency II while details of the Level 2 text are still to be finalised.
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The lobby of the Hotel Villa Magna in Madrid is an open yet somehow strangely labyrinthine space. The marble floor and dark walls ooze from the entrance through a set of glass cabinets displaying a mixture of jewellery and memorabilia, the sort these types of hotels have, into the vast open plan café. As it is the holiday season most of the guests are tourists and visitors from out of town, so our conversation about Solvency II is set to a background of light chatter and an occasional child’s shrill squawk.
We move on. There is only so much of the past one can rehash and draw lessons from without getting stuck in a rut. It would be more productive to try to take those lessons on board because Solvency II is not yet “in the bag”, as they say.The Guidelines, a mastertroke



Uncertainties casting shadows
The application of proportionality is all well and good but the final shape of the rules will also depend on the Level 2 text of the Directive, the so-called Delegated Acts. And as these have not yet been finalised another concern is that material changes to that text will affect the Guidelines. “We expect that the European Commission already considers that most of the framework is stable. As long as most of the framework is stable no fundamental changes should come and as long as that doesn’t happen you will have basically the same elements in the Preparatory Guidelines as in the final Guidelines.” All the indications so far from the Commission have been that it will look to limit the changes to the Level 2 text. At the last EIOPA conference Klaus Wiedner, Head of the Insurance and Pensions Unit of the European Commission, reinforced previous messaging that the Commission does not intend to reopen the entire text for negotiation. More recent indications, and a draft circulated to stakeholders in mid January, would suggest they have kept true to their word.