Saturday, June 5, 2010

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Disclosure of the letter to COVIP CRAIPI

Milan, May 30, 2010

CRAIPI Fund to inform members that the Commission for Supervision of Pension Funds (COVIP) sent a very detailed letter to the Board of CRAIPI in which you require, with particular speed, a range of information on the situation Fund. This letter was sent on May 14. On May 24 the Board of Directors of the Fund forward it to our Human Resources Department of the RAI and the trade unions National Secretariats.

Especially for the content, COVIP expressed some disappointment that in the past (from the point of time with the old Board of Directors chaired by Ms Anna Lagana), "despite the assurance of timely feedback, the Fund has done so only partially, sometimes as a result of reminders, to provide the answers due, which were not comprehensive ... "

arguments are given for which the COVIP (hence also the delegates representing the workers subscribers) awaits clarification within a period ranging from 15 to 40 days from the date of receipt of the letter. We
a brief summary (not least because the letter as well as being complex in the content is 6 pages long).

1) Relations between the Fund and internal funds RAI: \u200b\u200b
- about the relationship between internal funds and CRAIPI highlighted the liabilities of the RAI under the headings "welfare fund" and "supplementary pension fund business";
- Hypothesis of disequilibrium associated with the disbursement of pensions to retirees, even if only temporarily;
- contents and status of implementation of the "depreciation" of the payments to RAI CRAIPI;
- confluence Fund CERIPI (RAI Trade) in CRAIPI.

2) Financial management and accounting aspects
2.1) Results 2008
financial management - performance and cost: the cost will be highlighted in the results for the year. Also moving on investing those UCITS (Undertakings for Collective Investment Savings, such as asset management and investment companies) and the management direct and that of asset management, with purchases and sales as defined in the shareholders' initial and final, the various costs of management, securities, mutual funds and closed-end property, any losses incurred;
- Characteristics of asset management and insurance: guidelines, activation and termination of relationships, composition, currency exposure;
- Derivatives: it needs clarification on the presence of call options.
2.2) investment policies
It seems that the Fund has carried out a proper definition of the investment policy (financial objectives, strategic asset allocation and management methods). A clear definition of objectives and management methods not allow an assessment of the correctness of the criteria for the selection of managers, nor the transparency of the proceedings.
2.3) Composition of capital
The prevalence of investment in mutual funds raises doubts with respect to the difficulty of ascertaining the risk management, including the costs of commissions that appear, on first glance, particularly high if compared to the average value. We require a thorough reconnaissance of all the components of capital to the most recent date that takes into account all financial instruments held (including derivatives and insurance policies).

3) Compliance procedures and formalities required by law
is expressed a lack of respect of procedures and formal requirements. For example, are lacking the information and explanations relating to the requirements for the renewal of the Board and the verbalization on the outcome of the elections, the existence of legal requirements on the part of members of boards of management and control as well as manager of the Fund.
Even for statutory adjustments should be given, most attention in procedures relating to the amendment of existing statutes of the pension funds.
Moving the deadline for approving the budget by April 30 (provided by the scheme of negotiating pension funds) to June 30 would not sufficiently motivated.

4) Profiles of transparency in dealings with members
not yet complied with requests from the Commission. With reference to:
- the solutions for the communications to be disseminated to potential members and those to be sent annually to members;
- the outcome of the assessments made according to the document containing the SLC-CGIL demands for transparency, budget and organization of Fund;

Finally given the publication of a letter from an ex-member (since retired) who has applied for the award of the benefit, but laments the lack of perception of the summary.

COVIP The letter is put to the attention of boards of management and control, as well as manager of the Fund.
letter signed by the President of COVIP Antonio Finocchiaro


For our part as delegates representing the workers CRAIPI of Milan, but in general the SLC-CGIL, we believe we have pursued the right path (given by the above considerations COVIP): requests for clarification and transparency repeatedly raised with the previous Board, and now comes back with the new Board of Directors (given the short time that this had) is a shortest path of respect for all employees enrolled. This operation, above all, the credibility and long-term sustainability of the Fund.

will keep you informed.

Mauro Giorgio Zorzan
Calabria
delegates CRAIPI Milan

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