HAVE YOUR SAY: Pension fund and investment experts have been vocal in their initial criticism, and subsequent praise, of Solvency II proposals, which are now expected to exempt pension funds from meeting tighter funding levels under EU law.

But questions have begun to surface asking whether pensions funds should indeed be required to meet the same standards as insurance companies, if they are allowed to sell insurance too - as may soon be the case in the Netherlands.

If you would like to contribute to the debate, send your comments to carolyn.bandel@ipe.com or julie.henderson@ipe.com, and we'll include your comments in this discussion. (Please advise in advance if you would prefer to use a pseudonym upon publication)

Have Your Say: Commenting on the recent IPE story - CEIOPS changes direction on Solvency II - Hasko van Dalen, company adviser on social security and pensions at Nationale Nederlanden, said:

"It is very sad to notice that CEIOPS is changing its direction. When Solvency II will not be applied to pension funds, there will be no level playing field for pension provision. We think that is the wrong direction. The discussion about the solvency regime should focus on the type of product that is provided (in this case pensions) and not on the institutions that provide them. If there is a well-reasoned argument to exclude pensions from the Solvency II regime, this should apply to all pension provision, regardless who provides them. That is the only decent way to get to a level playing field.

"Establishing a level playing field is especially important for the Dutch market, where industry wide pension funds still have a protected position and hold a monopoly for their branch.

"Furthermore there is no reason at all to exclude pension funds from Solvency II as soon as they are allowed to provide insurance products. Until now, there has been a strong demarcation between the territories of pension funds and insurers. The Dutch industry-wide funds tried to burst through this barrier, but the report on the demarcation between insurers and pension funds by the Commission Staatsen in 1999 resulted in a cease-fire between insurers and pension funds.

"Recent proposals by the Ministry of Social Affairs and Employment will end this cease-fire. The insurers are digging up the hatchet, now that Minister Donner will allow pension funds to cover unemployment benefits for partially disabled people. He will even allow pension funds to provide bonuses and other financial incentives when they return to work or expand their working hours, within their remaining work capacity. In the eyes of the insurers, the unemployment benefits are the territory of property and casualty insurers and have nothing to do with pensions. If, indeed, pension funds will be allowed to provide such unemployment benefits, there will be no valid reason to exclude them from Solvency II anymore.

"Moreover, the provision of ‘back to work' bonuses will make pension funds an instrument of labour market policy. No reason anymore to regard them different from other institutions that operate on the labour market."

If you have any comments you would like to add to this or any other story, contact Julie Henderson on + 44 (0)20 7261 4602 or email julie.henderson@ipe.com