Answers to the European Commission on the ... - Eiopa - Europa

well as <strong>the</strong> question of transferability of capital within a group.
CEIOPS will provide advice on this question in its draft answer <strong>to</strong>
CfA 19.
Qualitative requirements
18.46 Quantitative capital requirements should be supported by and
embedded in robust qualitative requirements. CEIOPS advises <strong>the</strong>
<strong>Commission</strong> Services that <strong>the</strong> FCD would appear <strong>to</strong> offer a good
basis for <strong>the</strong> drafting of <strong>the</strong> relevant provisions covering qualitative
requirements in <strong>the</strong> Framework Directive. Comparability also in this
field with <strong>the</strong> FCD would fur<strong>the</strong>r support <strong>the</strong> aim of a level playing
field in financial services. CEIOPS in particular supports <strong>the</strong> inclusion
of more demanding provisions on capital adequacy policies (Art. 6
FCD), risk concentration (Art. 7 FCD) and internal control
mechanisms and risk management processes (Art. 9 FCD).
Allocation of supervisory responsibilities and co-operation
18.47 CEIOPS will address <strong>the</strong> issue of allocation of supervisory
responsibilities and supervisory instruments and powers of
intervention deemed necessary within a group context in more detail
in its answer <strong>to</strong> CfA 21 (Co-operation between Supervisory
Authorities). Even so, CEIOPS advises that Section 3 of <strong>the</strong> FCD –
"Measures <strong>to</strong> facilitate supplementary supervision" – will be an
important input in<strong>to</strong> that process.
Institutions with a parent undertaking outside <strong>the</strong> Community
18.48 CEIOPS also notes that <strong>the</strong> FCD addresses explicitly <strong>the</strong> situation of
institutions with a parent undertaking outside <strong>the</strong> Community.
CEIOPS would expect that <strong>the</strong> Framework Directive will also explicitly
address this situation.
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