pAV Reform: Feedback on the Discussion Draft of a Regulation on Costs and Information Obligations under the German Retirement Savings Contracts Certification Act (AltvKInfV)

1. Clarification in Section 7 as to whether the figures to be presented constitute an (exhaustive?) list of permissible cost categories or whether only requirements regarding their presentation are being addressed.

Particular attention should be paid to the following:

• Clarification that acquisition and distribution costs on transferred capital are not permissible, in order to avoid the associated incentives for the systematic transfer of already existing contracts.
• Consideration of government allowances (subsidies) as a possible cost reference base.
• Clarification of the term “return-reducing effect”.

You can find more on this topic on the German website aktuar.de.