TRANSITIENIEUWS – DNB workshop invaarmelding geeft sector handvatten voor invaarmelding

On 8 November 2023, representatives from 22 pension funds and 7 pension execution organizations (PUOs) attended a workshop at DNB on the process of „invaren“ notification (translated with “inward” notification) and filling out the inward template. DNB initiated this workshop to contribute to an effective and efficient transition process for pension funds. The discussion included the necessity of the inward template and practical tips for its completion.
The inward template serves as a checklist for funds to ensure that the underlying documentation in the notification covers all legal requirements. The template’s questions are derived directly from the law, providing an overview that is crucial as not all requirements are mandatory components of the implementation plan. By summarizing all requirements in one template, it is expected that both funds and DNB will spend less time determining if an inward dossier is complete.
The template is a mandatory component of an inward notification. During the workshop, important tips and considerations were discussed, including:
– Evaluation whether to take the risk of submitting a notification exactly six months before the intended filing date. If the dossier is incomplete at the time of submission, the fund does not meet the legal obligation to submit the notification at least six months before the intended filing date. The legal submission period starts only when the dossier is complete.
– Inclusion of time and capacity in the planning to quickly and accurately respond to DNB’s questions, and be aware that an additional board decision may be needed in certain cases.
– Provision of independently readable answers to the template questions, with references to underlying documentation for further details. This aims to demonstrate compliance with the legal standards referenced in the template.
– If the notification refers to underlying documentation, it should be included with the submission.