Latin Private Wealth Management Summit

  |   For  |  0 Comentarios

Latin Private Wealth Management Summit
Foto: dsasso . Se acerca el Latin Private Wealth Management Summit

Next May 12-13, 2016, at the Trump Ocean Club in Panama City, Panama, marcus evans will host its Annual Latin Private Wealth Management Summit.

The Summit is the premium forum that brings together solution providers with the most recognized single and multi-family offices in LATAM in a private, luxurious venue, destined to create business and debate about solutions for the wealth industry in the region.

Attendants will explore topics and issues within the private wealth industry in the LATAM region. Topics that will be discussed include: Private Equity, Foreign Direct Investments, Family Conflict, etc.

Along with the content, there will be both formal and informal networking opportunities. The formal networking will be one on one meetings (pre scheduled) between investors and decision makers, to learn about new techniques and solutions to face the challenges in Latin America.  Between the presentations, round tables and meetings, attendees can also network during coffee breaks, meals and cocktail hours! All of this in a five star resort.

This Summit is directed to CIO’s, VP’s, Directors, Founders, and Investment Leaders from Multi Family Offices, Single Family Offices, and Investment Advisors.

For more information follow this link or contact Deborah Sacal.
 

Gravitational Pull of Big Brands: Latest Research on Asset Management Brands in Europe

  |   For  |  0 Comentarios

Macroeconomic uncertainty and unsettled markets drove European investors to choose the fund houses they knew and trusted. The latest Fund Brand 50 analysis of cross-border third-party brands shows no change to the top six groups but the gap between the brand leader, BlackRock, and its nearest rivals is widening. According to research group Fund Buyer Focus, BlackRock outscored its competitors on most of the brand attribute measures evaluated by fund selectors.

The independent study measures asset managers’ relative brand attractiveness across ten brand drivers to provide cross-border, local market and distribution channel rankings. Findings from the study include the increasing role of brand in the fund selection process and the recent migration of buyers to the bigger fund houses. Commenting on this, Diana Mackay, director of Fund Buyer Focus says: “When investor confidence is low, brand naturally becomes more important in the fund-buying process with investors seeking the comfort and perceived stability of larger, familiar names. The ‘safe houses’, and particularly the brand leader, benefited from this trend in extremely choppy markets. The power of brand was also evident in the stickiness of some groups’ positions even though their flagship products were out of favor.”

Outside the top ten rankings, pricing pressures and regulatory changes fueled support for passive providers. iShares and Vanguard had the biggest impact on the cross-border rankings. But it was Vanguard that was the fastest riser – improving its FB50 ranking by 13 places over the year.

Four new groups gained sufficient recognition to enter the top 50 with highest new entrant, last year’s boutique winner Flossbach von Storch, extending its brand reach into new markets and gaining 32nd place. Meanwhile, the US group, T. Rowe Price saw its investment in developing its retail presence realized by increased recognition in multiple markets and 46th position.

But it was not just about the brand giants. At the other end of the asset management scale, boutiques had another good year. The Nordic boutique Lannebo Fonder moved up two places to take the boutique brand crown. Lannebo Fonder’s success reflected a trend in this year’s rankings of investor appetite for generating yield from investing in local specialists.

“Interest in specialist alpha-generating managers remained strong, helping to put new and more established niche managers in the spotlight. But even for these small groups, fund selectors placed great emphasis on the importance of corporate consistency, ranking the stability of the investment management team as the most influential brand driver,” explains Diana Mackay.

Top 10 cross-border groups ranked by Total Brand Score

 

About the research

The Fund Brand 50 (FB50) report is sponsored by Broadridge and FERI EuroRating Services. The Fund Buyer Focus FB50 report is an annual study monitoring the influence of brand on third-party fund selection. The study is based on intensive interviews with nearly 1,000 of Europe’s most significant fund selectors in ten key markets. These selectors account for EUR 2.2 trn of third-party assets.

Fund selectors are asked to name their top three suppliers on the basis of ten brand drivers including: appealing investment strategy, client orientation, innovation and solidity. Answers to these and other preference questions are scored using an algorithmic process that produces a ‘Total Brand Score’, on which groups are ranked.

 The research is conducted by Fund Buyer Focus, the Berlin-based subsidiary of MackayWilliams LLP  (London).

AZ Quest: “We Believe Now Is The Perfect Time To Invest In Brazil”

  |   For  |  0 Comentarios

Santiago, Chile, will this week receive a visit from Walter Maciel, CEO at AZ Quest, an independent asset management boutique of Brazilian origin which, since April 2015, belongs to the Azimut group. The reason for this visit is simply to explain to Chilean investors why it may now be a good time to re-invest in Brazil. In a road show organized by AZ Andes, Azimut’s Chilean subsidiary, which was established in Santiago in August 2015, Walter Maciel will discuss the long-term opportunities offered by Brazil. In his interview with Funds Society, he reveals some of the keys factors to understanding why now is the right time to invest in Latin America’s largest economy, despite the country’s current economic crisis.

It has been almost one year since Azimut purchased a controlling stake in Quest Investimentos, how has the firm changed? Which products are now offered that were not offered before?

Now at AZ Quest Investimentos, we remain fully independent. Azimut wanted to acquire our expertise in the Brazil and, being an independent asset manager as well, understands the importance of us conducting business as usual, preserving our investment process and retaining our team of professionals, and agreed to preserve that independence as per the contract we signed.

The deal increased our fire power to bring more management capacity, offering other professionals the same conditions pertaining to our deal. Last November we brought Credit Suisse Brazil’s former Credit Head Portfolio Manager and team. In three months we have added a new family of very conservative high grade credit funds and raised close to BRL 500 million.

Your largest funds by asset under management (according to the data available on your website), are the AZ Quest Acoes FIC FIA, the AZ Quest Total Return, and the AZ Quest Yield, would you please explain why have there been more successful than the other ones? Is there any other particular fund that has significantly increased its assets under value?

The credit funds as per the answer above. AZ Quest Acoes is the flagship fund of the long-only all cap family, that includes exclusive mandates for local Institutional Investors and holds around BRL 1 billion of AUM. AZ Quest Acoes has outperformed the Ibovespa Index every single year since inception in June 2005. In 10 years, the fund accumulates 467% net of all fees vs 67% of the Ibovespa.

Do you have any type of interaction with the other Azimut firms in Brasil, AZ Legan and AZ Futurainvest?

We are part of a single project, albeit independent. AZ Futura is now Azimut Brazil WM, a wealth management firm. AZWM is our own distribution arm, offering their individual clients an open platform and with profound knowledge of the Azimut funds (including AZ Quest funds). Our main job is to provide them with a diversified shelf of quality products and their main contribution is to concentrate in our funds and provide us AUM stability.

What is the purpose of this visit to Chile and AZ Andes? Do Chilean Investors have a particular interest for investing in Brazil or any of your funds?

Chilean investors have always had investments in Brazil. Unfortunately, in the last few years the bad economic policies, the greater intervention of state in the macro and sector levels have led Brazil to a major recession and lack of credibility, leading foreign investors, including Chilean, to divest and stay away. We believe this is the perfect time to invest in Brazil.

This past month the real has finally shown a slight recovery against the dollar, as politic turmoil keeps affecting Brazilian economy, are there any signs of improvement?

In the last four recessions in Brazil, since 1980, the investor that was able to enter the market at least three months prior to the inflection of the economy on quarter over quarter basis, made money every single time, in average USD + 60% in 12 months. We believe that inflection will occur by the end of the year.

Furthermore, we believe we are facing the end of both an economic cycle and a political cycle as well. The Brazilian society has changed profoundly. 25 years ago 65% of the people belonged to the informal economy and received transfers from the government. Today, 68% of the people are formalized, holding bank accounts and having access to credit.  They pay taxes and demand return of those taxes, decent infra-structure and good public services.

The new cycle will be based on investments and on diminishing the size of the state. There will be a wave of concessions, privatizations, revision of benefits like the social security and no tolerance with corruption on the private or the public sector. We believe the Brazilian investment theme is a long term one.

Is the Fed’s Credibility at Stake?

  |   For  |  0 Comentarios

The Fed’s dovish turn coming out of its March 15-16 meeting took many market participants by surprise. The Federal Reserve’s median projection for Fed Funds rate increases in 2016 fell from four in December to two, reflecting concerns about the impact of lower global growth and tighter financial market conditions on US GDP and inflation.

The median forecast for core PCE inflation at the end of 2016 remained unchanged at 1.6%, while the forecast for headline PCE fell from 1.6% to 1.2%. Finally, perhaps in recognition of relatively moderate wage inflation, the estimate for longer run median NAIRU (non-accelerating inflation rate of unemployment) was reduced to 4.8% from 4.9%.

The Fed took these decisions despite having up to the minute economic and market data that should have, in our view, allayed their concerns about the impact of both global growth and tighter conditions on US GDP and inflation. Recent US GDP, employment and inflation data have remained stable or are somewhat better than December levels, despite lower global growth. Having recovered from the early year sell-off, financial conditions on March 15, the day prior to the release of their statement, remained similar to those observed in December, when the Fed decided to raise rates. After reviewing the available data, one may conclude that either the Federal Reserve has erred in its current decision, and has given up some of its flexibility to raise rates, or that the Fed decided that their December hike was a mistake.

Below, we have highlighted a number of relevant economic and market levels at December 16, following the release of the Fed’s December statement and projections, and on March 15, prior to their release of their March 16 statement and projections.

Neuberger Berman Trust Company Names Richard Gardiner Chief Investment Officer

  |   For  |  0 Comentarios

Neuberger Berman Trust Company Names Richard Gardiner Chief Investment Officer
Foto: Terry Johnston . Neuberger Berman Trust Company nombra CIO a Richard Gardiner

Neuberger Berman has announced that Richard Gardiner has joined the firm and is appointed chief investment officer of Neuberger Berman Trust Company, an affiliate of Neuberger Berman. Mr. Gardiner will also lead the firm’s Investment Strategy Group and join the firm’s Asset Allocation Committee.

As part of his role within the $11.4 billion Neuberger Berman Trust Company, Mr. Gardiner will work along with Neuberger Berman’s wealth advisors and trust officers on high-net worth individual and foundation and endowment clients. With oversight of asset allocation, manager selection, and portfolio construction, Mr. Gardiner and the Investment Strategy Group will identify the most appropriate managers and investment strategies across multiple regions to provide the most optimal outcomes for Neuberger Berman clients.

“Richard’s skill set complements and enhances our approach to wealth management and investing, including traditional and alternative investments. His diverse background working in wealth management and in alternative investment strategies for a wide range of clients is a great match for his role as chief investment officer of the Neuberger Berman Trust Company. We are delighted to have him join us in that position as well as leading the firm’s Investment Strategy Group,” said Erik Knutzen, chief investment officer of multi-asset class portfolios at Neuberger Berman.

Prior to joining the firm, Mr. Gardiner was a consultant at the Reservoir Capital Group and chief investment officer and co-founder of an independent wealth management firm. Earlier, Mr. Gardiner was at Man Investments as head of Arbitrage & Credit and a member of the firm’s Investment Committee. Before joining Man, he was responsible for convertible sales and trading at J.P. Morgan and Goldman Sachs. Currently, Mr. Gardiner is a board trustee of the Emma Willard School and a member of the school’s Investment Committee and Finance & Audit Committee. Mr. Gardiner graduated cum laude from Yale University and earned his M.B.A. from Harvard Business School.

Capital Group Opens Amsterdam Office and Hires Country Marketing Manager

  |   For  |  0 Comentarios

Capital Group Opens Amsterdam Office and Hires Country Marketing Manager
CC-BY-SA-2.0, FlickrFoto: Bastiaan, Flickr, Creative Commons. Capital Group abre oficina en Ámsterdam y ficha a Martin Hofman como Country Marketing Manager para Benelux y regiones nórdicas

Capital Group, one of the largest and most experienced investment management firms worldwide, has announced the launch of its office in Amsterdam, as well as the appointment of Martin Hofman as Country Marketing Manager for the Benelux and Nordics regions.

Capital Group continues to focus on delivering high-quality long-term investment services to investors and institutions throughout Europe. The launch of the Amsterdam office and appointment of Mr Hofman, alongside other recent investment and business development hires, highlight this commitment.

Speaking at the office opening last night in Amsterdam, Rob Lovelace, Senior Member of Capital Group’s Management Committee and a Portfolio Manager, commented: “Capital Group recognises the importance of enhancing its relationships on a global, regional and local basis, in order to build upon its long-standing heritage. Our Dutch office is the latest in a series of new European offices we have opened over the past two years and is an essential part of our ambition to deliver long-term, reliable asset management services for Dutch, and European, investors, as well as expanding our global footprint.”

Mr Hofman will be based in the Amsterdam office and joins Feike Goudsmit and Marnix van den Berge, who respectively lead Capital Group’s business development activities in the Benelux institutional and financial intermediaries markets.He will play a key role in expanding Capital Group’s services in the Benelux and Nordics regions.

Mr Hofman joins Capital Group from Columbia Threadneedle Investments, where he began as Regional Marketing Manager for the Benelux and Nordics regions in 2008. Since 2014, he has been responsible for leading the institutional marketing activities in the EMEA region, including strategy planning, and development and execution of regional and global campaigns. 

Capital Group has also continued to expand on its European operations by making several new appointments in the past year. These include the appointments of Christophe Braun in January 2016 and Julie Dickson in December 2015 as investment specialists in the London office.

Capital Group currently has sales branches in eight locations across Europe: Amsterdam, Frankfurt, Geneva, London, Luxemburg, Madrid, Milan and Zurich.

Unravelling the Bond Market Impact of the ECB’s Latest Policy Measures

  |   For  |  0 Comentarios

The bond market’s response to the European Central Bank’s (ECB) latest easing measures was immediate and broadly positive, but the implications for the real economy are harder to gauge.

The market’s immediate reaction to the latest easing measures announced by the ECB on 10 March was, in some respects, counter-intuitive. Most investors will be used to seeing government bond yields fall in the wake of greater-than-expected policy easing, but in this instance, 5-year and 10-year Bund yields rose steeply.

This is because Bund yields had already been driven to extremely low levels during January and February’s firmly ‘risk-off’ market tone. The ECB’s latest support measures cheered markets, and resulted in some of the ‘safety premium’ embedded in Bund valuations being reduced.

A boost for bond bulls

Indeed, there is little doubt that the latest steps from ECB President Mario Draghi are positive for financial markets. The first phase of ECB asset purchases, in early 2015, focused on buying government debt. This pushed government bond prices up and nudged investors into riskier assets to replace the lost yield.

The fact that risk assets – currently non-banking investment grade corporate bonds – are now included in the expanded €80 billion-a-month asset purchase scheme, means that the ECB is driving down the cost of risk more directly. We expect investment grade corporate bonds will continue to perform strongly from here. Credit spreads should narrow, and investors will reach for higher-yielding corporate assets. This impact has also been positive for equity markets, because the cost of capital has improved.

Will the changes make a “real” difference?

The implications for the real economy are less clear-cut. A high proportion of the liquidity which should have entered the US economy through its own QE schemes became ensnared in the banking system, and the velocity of money didn’t appreciably pick up. There was no real spike in lending, and regulatory changes meant that the mortgage market remained somewhat impaired. Of course, if QE had never been implemented, then the condition of the US economy could have been far worse.

In our view, the likelihood of the ECB achieving its vaunted 2% inflation target, even within five years, is low. The output gap, which bears down on both worker and company pricing power, is too significant for prices to improve to the 2% target growth rate. Economic growth – currently forecast to be around 1.4% in 2016 – is insufficient to close this output gap quickly. The ECB, in our view, will need to do more.

The waiting game

This, then, begs the question of why Mario Draghi followed up the latest policy announcements with the suggestion that further rate cuts are “unlikely”. The euro, having fallen after the deposit rate was reduced, rose as soon as Mr Draghi made the comment. However, we see his observation as largely practical. Running a negative interest rate policy is unlikely to work in the long term, as it would encourage investors to hoard cash. Excessively negative rates mean that even the cost of insuring cash deposits ‘in-house’ could be less significant than the cost of depositing funds with the ECB.

However the ECB proceeds from here, it seems unlikely that the deposit rate will be the tool that they reach for. For now, we believe that the amended policy environment has bolstered existing support for risk-asset markets and settled simmering nerves. Patience will be required to see quite how effective the measures will be for stimulating more economic growth.

Column by Schroders’ Gareth Isaac

Judging Fed Policy Path Requires Keeping One Eye on Domestic Economic Fault Lines and Another on Those Abroad

  |   For  |  0 Comentarios

The policy statement released on Wednesday by the Federal Reserve’s Federal Open Market Committee (FOMC) represents a continuation of the “wait-and-see” trend anticipated by the market. The Fed continues to keep the door open to interest rate policy normalization, which it began in December, with the pace of change dictated by economic data and financial conditions. Overall, economic data in the U.S. have marginally deteriorated since the central bank embarked on rate normalization away from emergency conditions, but the Fed’s mandated objectives of full employment and price stability are still largely on track for continued tightening this year, even if at a slower pace than anticipated. Indeed, the language of today’s statement highlighted some of those concerns, for example mentioning that “business fixed investment and net exports have been soft.” Also, vitally, the FOMC stated that “…global economic and financial developments continued to pose risks,” underscoring the extent to which external economic and financial market stresses can influence Fed policy today.

Further, the FOMC’s changes to its Statement of Economic Projections (SEP) also highlight the likely slower path of interest rate change this year, and some continued uncertainty over U.S. growth prospects in a world of slowing economic growth overall. For example, the Fed downgraded real GDP growth projections in 2016, from the 2.4% it had assumed in December to 2.2% today, with 2017 growth also witnessing a modest reduction.  We agree that the data will continue to marginally deteriorate from here, which justifies the Fed’s lowered anticipated “dot-plot” path of one or two more hikes by year-end, versus the four implied by the December SEP. We believe the door was open to beginning this normalization process a couple years ago, and to some extent the Fed missed its optimal window of opportunity to normalize rates in an easier manner. Today, the central bank must contend with payrolls growth that is likely peaking, challenging financial market conditions from abroad, and an inflation rate that appears to be firming.

Unlike some others, we don’t believe the U.S. economy will enter a recession anytime soon, but labor market growth will slow in the quarters ahead, as companies are scaling back expenditures of all kinds (capital expenditures, hiring, and inventory-builds, for example), as their top-line revenues and earnings decelerate. Moreover, changes to headline payrolls tend to lag corporate earnings/profits changes by a six-month time frame, so the rolling over of the growth rate of corporate profits in recent quarters should feed through to a worsening jobs picture by the back half of 2016. Further, temporary hiring has started to slow, which historically has been a signal of future weakness in payrolls growth, as it hints at changes in the supply/demand of labor. All these dynamics put the Fed in a difficult position regarding normalizing rates, since the economic cycle may be moderating as the central bank seeks to raise rates.

We are not arguing that these dynamics represent a tangible economic weakness that threatens the recovery, but rather that slowing payrolls growth is likely to keep the Fed’s rate normalization path more contained than outlined at the December meeting, and perhaps even than the path implied by today’s SEP. We also think there is a tangible wage and inflation lag, and believe that this will also play out going forward, as we have recently witnessed with current inflation data, such as Average Hourly Earnings, the CPI and Core PCE readings.

Generally speaking, it is not the U.S. consumer that concerns us, as consumer spending is likely to support the economy on the back of very strong employment growth over the past few years and potentially improved wage growth in the year ahead. What does concern us, though, is another potential economic fault line, the fact that a variety of corporate sector metrics have been disappointing of late. Years of extraordinarily easy monetary policy stoked corporate borrowing and financial engineering, and some companies are now struggling with the increased debt load as revenues and profits begin to roll over (see graph).

Additionally, what is ironic is that while everyone (understandably) focuses on the domestic economic situation, the factor that has opened the door again for the Fed to keep moving rates this year, which seemed impossible only a few weeks ago, is the improvement in financial conditions. That has largely come on the heels of China policy makers making a decision to not aggressively devalue their currency to protect against capital flight, an aggressive ECB, and a stabilization in oil’s persistent price descent. Thus, while we think that the U.S. data is marginally deteriorating, and may continue to do so, we think that financial conditions, including the potential strength of the USD (and its related influence on global growth and corporate earnings), will be one of the primary determinants of whether that door for further Fed moves stays open or gets slammed shut due to global economic/market duress.

Hence, keeping an eye on the Fed for market price-action going forward may also mean keeping the other eye focused outside the U.S., and somewhat outside the Fed’s core dual mandates of employment and price stability. Indeed, the path of monetary policy change in the year ahead may be determined as much by what occurs outside the country’s borders than within them; more so than any time in recent history.
 

Growth is not a Valid Reason for Investment, not Even for Emerging Markets

  |   For  |  0 Comentarios

For many years, a constant within the capital markets was that emerging markets equalled growth. This also served as the universal argument for investing in emerging markets. For Marc Erpelding, fund manager of the BL-Emerging Markets fund, emerging markets will experience a slower rate of growth in the future.

“The days of “simple” growth, backed by state investment programmes and exports based on low wage levels are pretty much gone. Going forward, the service sector and the domestic consumption will play an ever greater role. However, studies have shown that there is no link between economic growth and stock market performance. So “growth” is not a valid reason for investment, not even for emerging markets.” Therefore, according to Erpelding, the slowdown in growth should not necessarily be considered a negative development.

His investment process includes focusing on firms “which are in a position to create added value in the long term for their customers and shareholders; ideally, they can do this independently of macroeconomic trends. Firms that have high barriers to entry, present robust balance sheets and generate strong positive cash flows generally have the advantage of seeing less correction in bear markets and often emerge on top after crises. In addition, we only invest in easy-to- understand business models. It does not matter to us whether or not these companies are included in the index or what their weighting is.” This consistent investment approach can result in them being very underweight in financials or commodities. “We often find that banks lack transparency and, in the case of commodities firms, the investment decision tends to depend more on the commodity cycle than on the company itself.”

In the years 2010 to 2014, the MSCI Emerging Markets index mainly moved sideways. “However, we are less interested in the direction of the index than in the price performance of the high-quality companies we are tracking. Since May 2015, we have seen sharp corrections in this segment too, which we have used to raise the equity ratio from around 68% to approximately 84% at present. This is the highest equity ratio in the fund since the financial crisis. The corrections have led to more attractive valuations for many high-quality firms and allowed us to add to existing positions or initiate on new companies. These are purely bottom-up decisions. We will increase the equity ratio further, should high- quality companies increasingly undergo correction.. In an asset class that is (unfortunately) still regarded as satellite and therefore heavily depends on investors’ appetite for risk, we think this countercyclical approach makes great sense” he concludes.
 

Buy and Sell Side Join Forces in Support of STS Securitisation

  |   For  |  0 Comentarios

The Association for Financial Markets in Europe (AFME), the European Fund and Asset Management Association (EFAMA), the International Capital Market Association (ICMA) and Insurance Europe have issued a joint paper backing efforts by EU policymakers to develop a robust and successful framework for simple, transparent and standardised (STS) securitisation.

In line with the Commission’s flagship Capital Markets Union initiative, the associations believe that a new framework for securitisation could play a pivotal role between banks’ financing and capital markets, enabling much-needed non-bank funding alternatives and providing investors with high-quality fixed income securities and attractive yields.

In the joint paper, the organisations affirm that securitisation is an important element of well-functioning financial markets and call for securitisation to be treated on a level playing field with other forms of investment. They highlight their shared views on the key points for EU policymakers to consider in their development of the new framework.

Simon Lewis, Chief Executive of AFME, said: “The development of a high-quality securitisation market in Europe is an integral part of the Capital Markets Union and contributes to the Commission’s objectives to revive the real economy through increased financing and prudent risk transfer. For the European securitisation market to be safely and successfully rebuilt, the new framework must be attractive for both issuers and investors whilst operating under a strong but fair and rational regulatory regime. We are delighted to unite with investors and other market participants on this important policy initiative.”

Peter De Proft, Director General of EFAMA, commented: “EFAMA is acutely aware of the generational opportunity offered by the Capital Markets Union in restoring economic growth in Europe. The Commission’s securitisation package, as an essential component of a successful CMU, could potentially generate billions in additional funding for the economy and could act as a key driver in encouraging investor participation in European capital markets. This joint initiative of the buy-side and sell-side is testament to the sheer emphasis we believe should be placed on achieving a balanced securitisation framework which will work for our markets, our investors and Europe as a whole.”

Martin Scheck, Chief Executive of ICMA, said: “Securitisation represents a crucial asset class for investors and borrowers in Europe. As an association with both buy- and sell-side members we have strongly welcomed efforts to revive securitisation as a key element in financing the drive to restore jobs and growth in Europe. This joint paper underlines our commitment to supporting an appropriately designed framework to achieve this.”

Michaela Koller, Director General of Insurance Europe, said: “Insurers must have access to a wide range of assets in order to diversify their portfolios, and this includes a need for high quality securitisations. Steps to identify good securitisations have already been made under Solvency II and the Commission’s proposal is a continuation of this, with some important improvements. However, further improvements are needed, some of which this paper outlines. From an insurer’s perspective, we are calling for a much needed revision of the capital treatment of securitisations under Solvency II.”