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APG Groep N.V.

APG

The objectives of the company are to participate in, to manage and to finance enterprises wich offer and perform services or cause the same to be performed in the fields of pensions, insurances, asset management, reintegration advice, the keeping of the accounting records related to the foregoing and the keeping of accounting records in general, the provision of financial services in the widest sense of the word and carry on the insurance business, or participate in enterprises carrying on the insurance business, all this in the widest sense of the word, as well as to provide security and encumberassets as security for the payment of debts of the company or group companies.

Lobbying Activity

Meeting with Joost Korte (Director-General Employment, Social Affairs and Inclusion)

27 Nov 2019 · Next CMU Report

Meeting with Olivier Guersent (Director-General Financial Stability, Financial Services and Capital Markets Union) and KfW Bankengruppe and

8 Jul 2019 · Capital Markets Union Working Group

Response to Review of the European Supervisory Authorities

23 Jan 2018

APG is a Dutch service provider for several major pension funds. We support making changes to the system and capacities of the ESAs. We do however feel that some of the proposed changes are overshooting. National supervision In our view the ESAs should not take a ‘silo-approach’ but must also have eye for the different types of regulation applying to the same market participant(s) and how these interact. Supervisory convergence should not result in restricting current powers and tools of national competent authorities (NCAs). The importance of the knowledge of NCAs about national specificities should be recognized. NCAs should remain able to set their priorities and should never be forced to follow the ESAs Strategic Supervisory Plans. Pensionfunds are organized very differently from Member State to Member State. In IORPII NCAs have the sole mandate to supervise pensionfunds and should therefor be independent with their policies for supervision in their jurisdictions. Industry funding We oppose replacing ESA NCA-contributions by industry contributions. A payment mechanism purely based on size can in our view not be objectively justified. Other factors, such as systemic risk contribution, the costs of national supervision and an assessment of those who ultimately bear these costs also need to be taken into account. Its our strong opinion that there should be no ESA industry funding requirements for financial market participants that are indirectly subjected to ESA supervision. If such system would nonetheless be adopted, a proper investigation as to how this should work, should be undertaken first. Data collection Reducing and streamlining reporting requirements should be a high priority. Simplification should be achieved where possible and an overarching assessment of burdens should be made. Pensionfunds and their dedicated asset managers have increasingly been subjected to (burdensome and costly) reporting requirements reporting the same (type of) information twice, both to NCAs and to (one or more) ESAs and/or different interpretations of what is adequate information, should be avoided. The starting point should remain the so-called ‘one-stop-shop’-concept. The use of alike classifications and definitions for all types of pensionfunds’ reporting requirements is equally important. Stress tests We are not in favor of the publication of individual stress test results, because they are to a substantial degree dependent on the widely differing national regulations of the Member States in which they are based. ESG factors As a long-term responsible investor, APG highly values ESG-factors. . We believe the ESAs have an important role in overseeing how financial institutions integrate sustainability considerations. It will then be important to make clear what the exact powers of the ESAs would be. For instance, if the ESAs would indeed be empowered to give guidance as to how sustainability considerations can be effectively embodied in relevant EU financial legislation, it should be safeguarded that this cannot translate into any powers for the ESAs to influence the content of such considerations. Market standards and for instance the recommendations of the EU HLEG on Sustainable Finance should remain leading. Stakeholder input ESAs should gain input from (industry) stakeholders that are able to provide very useful input on increasingly complex topics. Furthermore Stakeholder Groups should include sustainability experts to inform policy making. More bilateral meetings between the ESAs and relevant stakeholders would be helpful as well. We subscribe to the advisory role of the OPSG and to separate stakeholder groups for occupational pensions and insurance undertakings. Prolonging OPSG members’ mandate would contribute to the continuity and the quality of the OPSG-work. The (asset managers of) pension funds should be represented in ESMA’s Securities and Markets Stakeholder Group.
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Response to Review of the European Supervisory Authorities

23 Jan 2018

APG is a Dutch service provider for several major pension funds. We support changes to the system and capacities of the ESAs. We do however feel that some of the proposed changes are overshooting. National supervision In our view the ESAs should not take a ‘silo-approach’ but must also have eye for the different types of regulation applying to the same market participant(s) and how these interact. Supervisory convergence should not result in restricting current powers and tools of national competent authorities (NCAs). The importance of the knowledge of NCAs about national specificities should be recognized. NCAs should remain able to set their priorities and should never be forced to follow the ESAs Strategic Supervisory Plans. Pensionfunds are organized very differently from Member State to Member State. In IORPII NCAs have the sole mandate to supervise pensionfunds and should therefor be independent with their policies for supervision in their jurisdictions. Industry funding We oppose replacing ESA NCA-contributions by industry contributions. A payment mechanism purely based on size can in our view not be objectively justified. Other factors, such as systemic risk contribution, the costs of national supervision and an assessment of those who ultimately bear these costs also need to be taken into account. Its our strong opinion that there should be no ESA industry funding requirements for financial market participants that are indirectly subjected to ESA supervision. If such system would nonetheless be adopted, a proper investigation as to how this should work, should be undertaken first. Data collection Reducing and streamlining reporting requirements should be a high priority. Simplification should be achieved where possible and an overarching assessment of burdens should be made. Pensionfunds and their dedicated asset managers have increasingly been subjected to (burdensome and costly) reporting requirements reporting the same (type of) information twice, both to NCAs and to (one or more) ESAs and/or different interpretations of what is adequate information, should be avoided. The starting point should remain the so-called ‘one-stop-shop’-concept. The use of alike classifications and definitions for all types of pensionfunds’ reporting requirements is equally important. Stress tests We are not in favor of the publication of individual stress test results, because they are to a substantial degree dependent on the widely differing national regulations of the Member States in which they are based. ESG factors As a long-term responsible investor, APG highly values ESG-factors. . We believe the ESAs have an important role in overseeing how financial institutions integrate sustainability considerations. It will then be important to make clear what the exact powers of the ESAs would be. For instance, if the ESAs would indeed be empowered to give guidance as to how sustainability considerations can be effectively embodied in relevant EU financial legislation, it should be safeguarded that this cannot translate into any powers for the ESAs to influence the content of such considerations. Market standards and for instance the recommendations of the EU HLEG on Sustainable Finance should remain leading. Stakeholder input ESAs should gain input from (industry) stakeholders that are able to provide very useful input on increasingly complex topics. Furthermore Stakeholder Groups should include sustainability experts to inform policy making. More ad hoc bilateral meetings between the ESAs and relevant stakeholders would be helpful as well.. We subscribe to the advisory role of the OPSG and to separate stakeholder groups for occupational pensions and insurance undertakings. Prolonging OPSG members’ mandate would contribute to the continuity and the quality of the OPSG-work. The (asset managers of) pension funds should be represented in ESMA’s Securities and Markets Stakeholder Group.
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Meeting with Marianne Thyssen (Commissioner) and

14 Dec 2017 · Pensioenen, de sociale zekerheid en het beleid met betrekking mensen met een afstand tot de arbeidsmarkt

Meeting with Maarten Verwey (Director-General Structural Reform Support)

19 Oct 2017 · Cooperation on future technical support on pension funds

Meeting with Valdis Dombrovskis (Vice-President) and

5 Apr 2016 · Pension Funds

Meeting with Jonathan Faull (Director-General Taskforce on Article 50 negotiations with the United Kingdom)

5 Apr 2016 · UK Referendum

Meeting with Mette Toftdal Grolleman (Cabinet of Commissioner Jonathan Hill)

30 Mar 2016 · IOPS, CMU, Personal Pensions

Meeting with Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis)

22 Dec 2015 · NL pension funds and their role as investors

Meeting with Jack Schickler (Cabinet of Commissioner Jonathan Hill) and BlackRock and

24 Aug 2015 · CCP recovery and resolution

Meeting with Jonathan Hill (Commissioner)

30 Mar 2015 · Asset management issues