The proposed law provides a procedure for cross-border transfers.
The new legislation provides for four key roles that need to be covered by a pension fund:
- The risk management role (new role)
- An actuarial role (not necessary if the pension fund only manages fixed contribution plans)
- A compliance role
- An internal audit role
The risk management role is new and its importance should not be underestimated. The new legislation devotes the necessary attention to the risk management system, and pension funds are required to carry out their own risk assessment at regular intervals.
The new draft law imposes additional information requirements. All existing pension funds will need to review their current information and communication policies and make any necessary adjustments to meet the new requirements.
The legislator has provided transitional rules for existing pension funds, who need to appoint someone to the risk management role by 31 December 2019. Existing appointees in key roles may continue in place until 31 December 2020. After that, those responsible will need to be reappointed, or new managers must be designated in line with the prescribed procedures.