On 1 February 2011, the CEA (European Insurance and Reinsurance Federation) published its response to a recent (November 2010) European Commission consultation on certain Solvency II implementing measures. In the response, CEA re-iterates many of the views expressed in its recently published Solvency II paper (reported in Tracker last month), including that feedback from its members is that the current proposals are overly burdensome, complicated and costly. While the CEA acknowledges the benefits of introducing a risk-based approach, it emphasises the importance of the new system being workable for the industry.