On 3 January 2011, the European insurance and reinsurance federation, the CEA, published a paper on Solvency II. The paper highlights concerns that the Solvency II regime will place an unduly high burden on insurance and reinsurance undertakings, particularly small and medium-sized insurers. While acknowledging that the European Commission has taken some measures to counter-balance industry concerns, the paper stresses the importance for Solvency II implementing measures to be drafted carefully, in order to avoid undue complexity and administrative burdens, but maintain appropriate reflection of risk.