The German Association of Actuaries (DAV) welcomes the opportunity to provide comments on your questions regarding the topic “pAV/RVO: Corresponding application of Delegated Regulation (EU) 2017/653”. From our perspective, the application of the PRIIP Regulation to certified retirement pension products raises a large number of methodological questions that still require further clarification. Against this background, we consider it appropriate that a Pension Product Information Office should once again be established in the future, which would provide methodological clarifications in this context. We would be pleased to participate in further technical discussions with the Federal Ministry of Finance (BMF) and the newly established PIA as the process continues. We would also like to point out that the application of stochastic models, which may be developed and specified in the future for the purposes referred to in the Retirement Pension Reform Act, creates interdependencies with other areas of application. For example, some insurance undertakings also use the current industry standard for PRIIPs in Category 4 for their internal demonstration of appropriate customer benefit under the IDD and the requirements set out in BaFin Guidance Notice 01/2023 (VA) regarding conduct-of-business supervisory aspects for capital-forming life insurance products.
You can find more on this topic on the German website aktuar.de.
