German Banking Industry Committee

We recommend a harmonisation of the following definitions (page 4) or, moreover, a clearer definition: “net pension assets, net pension liabilities, “net benefit pension fund assets or liabilities" as well as “defined benefit pension funds".

Furthermore, due to the fact that the rationale for certain conclusions will be difficult to comprehend otherwise, we recommend a more detailed elaboration of the individual scenarios, e.g. the scenario featuring a regulatory deduction position/net pension asset or the scenario without a regulatory deduction position/net pension liability or defined benefit pension obligations which are not funded through plan assets."
Basically, we agree with the proposed methodology/approach (qualitative, quantitative, additional considerations).

However, in our preliminary understanding there is no recommended course of action for the legislative process.
We have strong doubts over the fitness for purpose of a regulatory deduction position (cf. our general comments above). Particularly the fact that the allocation of plan assets shall not be recognised directly in equity for accounting purposes (per plan assets to cash assets) speaks against a deduction of an asset surplus.
No, we do not agree (cf. our general comments, scenarios, b) and our response to Q3).
From the point of view of a company which previously applied the corridor method this is likely to be the case (cf. our general comments on possible constellations). „Defined benefit pension fund in EBA/DP/2014/01 point 34: cf. our response under Q1."
The analysis of the revised IAS 19 (2011) appears to be complete. However, this analysis was divorced from the potential scenarios (c.f. General Comments above); In our view, it is incomplete or, moreover, not sufficiently clear.
We are unfamiliar with the data on which the analysis is based. Hence, any assessment thereof would be premature.
Dirk Peters