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European Financial Services Round Table
Publication/Research Document

EFR response to Green Paper on Pensions
EFR Letter on the Pensions Green Paper consultation of the European Commission Referring to the Commission's Green Paper consultation on pensions we wish to express our long-standing interest in ensuring an effective pensions regime for Europe. The EFR has published several position papers on this important issue in the past and therefore we would like to share our thoughts with you. The EFR welcomes the Green Paper but has the impression that the Commission's analysis is often more comprehensive than the questions that result from it. This reinforces the impression given by the Green Paper that all the main providers of pensions are pension funds falling under the IORP Directive. EFR is keen to promote efficiency and competition within an internal market for pensions. For example, EFR's work on the 28th regime should also be revisited in connection with the Green Paper and the Monti Report. Even if cross-border pensions are a matter for the medium to long term, the foundations for this are being laid now in how the EU and the Member States go about reforming domestic arrangements. Therefore, the Commission's reflections on how to address pension reforms need to think beyond IORPs and the removal of geographic barriers to pension provision and embrace all providers of pension products. The absence of an internal market for pensions is due to a deeper fragmentation of Eu-rope's pensions rules. This not only impedes cross-border integration but generally reduces the scope for efficient pension provision within individual Member States. It also hampers the effective organisation and operation of financial services groups that rely on the interaction between multiple directives and national rules. Ultimately, the cost of this fragmentation is born by Europe's citizens.