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Dear Peter,

I think you missed the point. Insurance Europe indicates that the risk of the provider is not necessarily the risk of the scheme.

For example there exists DC schemes offered by the employer, where the employees can choose between different occupational pension products including products with a guarantee (DB products).

This also works the other way around: there exist DB schemes where the provider is solely the funding vehicle, not offering any biometric risk coverage or covering for guarantees.

In these circumstances, you should not look at the underlying scheme to regulate the provider but look at the risks covered by the provider and its activities linked to the scheme.

Please also remark that both DC and DB can apply to the insurance sector.

Kind regards,
Frederik