TWINNING INTERIM QUARTERLY REPORT

TWINNING INTERIM QUARTERLY REPORT number: 1

EUROPEAN COMMISSION

TWINNING PROJECTSINTERIM QUARTERLY REPORT

Project Title: Development and consolidation of the National Commission for Financial Markets’ operational and institutional capacities in the field of prudential regulation and supervision.Partners: The National Commission for Financial Markets

of the Republic of Moldova (CNPF) The Polish Financial Supervision Authority (KNF)Date: November 2015

Twinning Contract number: Moldova - ENI/2015/363-321

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General instructions

1. Overview

The Interim Quarterly Report/Final Report for the project comprises the following parts:

Section 1 Basic data on the project Section 2 Content: progress achieved in the implementation of the Twinning project during the reporting period and

schedule for the remaining periodSection 3 Expenditure: actual expenditure in relation to budgeted expenditure

2. General guidance

Throughout the entire Twinning project, at three-monthly intervals starting with the date of notification of endorsement / signature, the Project leaders may prepare Interim Quarterly Reports/Final Reports.

Interim Quarterly Reports/Final Reports cover both substance and Finances. The deadline for submission of the Interim Quarterly Reports/Final Reports cannot be altered – The first interim quarterly

report will most often refer to less than three months’ actual project implementation, since the arrival of the RTA in the BC and the beginning of the work schedule rarely coincide with the date of notification.

The MS Project Leader in co-operation with the BC Project Leader will submit, within the month following each quarter, the interim quarterly reports to the concerned authority (see 6.4 of the Twinning manual).

One copy of the Report must be sent at the same moment to the relevant Twinning Team in the Commission Headquarters The Report must be submitted in one of the following three languages: English, French and/or German.

3. Notice

The approval of the Report by the relevant authorities is without prejudice to the Commission's right to suspend the activities of a project, terminate an agreement or take any other appropriate step should subsequent verifications reveal problems or significant divergences from the work plan, the budget or the conditions of the Twinning Contract as approved.

The views expressed in this report do not necessarily reflect the views of the European Commission

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Twinning Contract number: Moldova - ENI/2015/363-321

Section 1: Project data

Twinning Contract Number ENI/2015/363-321

Project Title: Development and consolidation of the National Commission for Financial Markets’ operational and institutional capacities in the field of prudential regulation and supervision.

Twinning Partners (MS and BC) MS: Polish Financial Supervision Authority (KNF)

BC: National Commission for Financial Markets of the Republic of Moldova (NCFM)

Report Number: 1

Period covered by the report: 12 August 2015 – 11 November 2015

Duration of the project: 12 August 2015 - 11 November 2017

Rapporteur: Prepared by:

Joanna Lipowczan, Project Manager from the Polish Financial Supervision Authority

Grzegorz Wąsik, Resident Twinning Adviser from the Polish Financial Supervision Authority

Approved by:

Damian Jaworski, Project Leader from the Polish Financial Supervision Authority

Iurie Filip, Project Leader from the National Commission for Financial Markets of the Republic of Moldova

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Twinning Contract number: Moldova - ENI/2015/363-321

Section 2: Content

This section describes the activities of the project. It is divided in five sections.

2A – BACKGROUND

2B – ACHIEVEMENT OF MANDATORY RESULTS

2C – ACTIVITIES IN THE REPORTING PERIOD

2D – TIMING AND DELAYS

2E – ASSESSMENT

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Twinning Contract number: Moldova - ENI/2015/363-321

2A – BACKGROUND

This report covers the activities that have been carried out in the first quarter of the project, in the period of 12 August until 11 November 2015. This chapter comprises political developments directly linked to the subject of the project, the state of the achievement of project objectives and the state of project assumptions.

Overall objectives

Overall Objective and indicators of achievement (as in Logframe)

State of achievement/ problems encountered

Overall Objective: Development and implementation of the Risk Based Supervision System for the non-banking financial market participants, including capital market, insurance, pension funds and micro-finance based on the forecasting and evaluation of the risks and preventable consequences of some unfavourable events.Alignment with EU acquis and implementation of best practices of EU in regard to non-banking financial market supervision.

Development and implementation of the Risk Based Supervision System for the non-banking financial market participants, including capital market, insurance, pension funds and micro-finance based on the forecasting and evaluation of the risks and preventable consequences of some unfavourable events accomplished.

A better methodology and standards of supervision of the non-banking financial market including capital market, insurance, pension funds and micro-finance in Moldova will allow a more efficient and secure application of supervisory system based on the forecasting and evaluation of the risks. A well-functioning non-banking financial market in

At this stage the information on the progress in achieving the overall objective cannot be provided due to the inception period of the project implementation.

The project development is in the initial stage.

Within the reporting quarter the first project activities were implemented in line with the Twinning Work Plan, including: - kick-off meeting aimed at promotion of the project

and increasing the public awareness about project objectives, its purposes and implementation plan (i.e. Activity no 0.1);

- experts’ mission concerning development of conceptual framework of Risk Based Supervision in the non-banking financial markets (i.e. Activity no 1.1);

- experts’ mission concerning strengthening the capacities against market abuse, manipulation and insider transactions (i.e. Activity no 1.6).

The above activities state a base for further project development.

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Moldova will contribute to economic growth, poverty reduction and employment as well as overall security and stability of non-banking financial market participants.

Project purpose

Project purpose and indicators of achievement (as in Logframe)

State of achievement/ problems encountered

Project purpose:Development and maintenance of an appropriate and effective regulatory and supervisory framework in accordance with the EU legislation and best practices to enable prudential regulation and supervision on the non-banking financial market.Strengthening operational and institutional capacities of the NCFM accomplished.

Development and maintenance of an appropriate and effective regulatory and supervisory framework in accordance with the EU legislation and best practices to enable prudential regulation and supervision in the field of:

1. capital market and investment funds sector;

2. insurance companies sector;

3. savings and credit associations and pension funds sector.

Within the reporting quarter the achieving of project purposes has been initiated.

Review report with recommendations from the perspective of establishing risk-based supervision for insurance market was developed and provided to the NCFM.

Furthermore, in line with the project assumptions, the review of the NCFM’s capacity in the field of combating market abuse in the capital market (market manipulation and insider trading) and workshops for the NCFM and market participants were performed.The input provided by the MS experts shall contribute to establish a sound base to facilitate further efforts for development and maintenance of an appropriate and effective regulatory and supervisory framework in accordance with the EU legislation and best practices.

Thus, the NCFM capacities to regulate the non-banking financial market and strengthen its supervision functions in line with the EU acquis and best practices have started to increase .

Policy Developments

Speaking about the legal framework in which the Twinning project started to be implemented, we mention that in the period September – November 2015 the NCFM made significant efforts to promote in the Parliament the draft laws regulating the activity of insurance undertakings and pension funds. These draft laws will be examined by Polish experts during the future missions in order to provide their comments and amendments to the existing framework based on Polish experience in the field.

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Having the scope of improving the insurance legislation and accomplishing the Action Plan elaborated by the Council of Bureaux from Brussels, the NCFM has promoted the draft law amending the Law on Insurance no. 407-XVI of 21.12.2006 and the draft law amending the Law on compulsory motor insurance of civil liability no. 414-XVI of 22.12.2006.The amendments to the law on insurance refer to:

1.1. strengthening the financial stability of insurers, by applying a transparent and complete regulation of the measures used for improving the financial situation and for financial remediation of insurers;

1.2. diversification of the sanctions and penalties applied to insurers for violations and deficiencies identified that shall lea to the consolidation of the supervisory capacity of the financial market authority.According to the draft law, the strengthening of financial capacity of insurers (reinsurers) will be performed by early intervention of NCFM by applying:- financial recovery plan containing effective measures to improve the financial situation of insurers (reinsurers) and financial remediation.The draft law is under examination in the Parliament of the Republic of Moldova.The amendments to the Law on MTPL insurance provides a new approach for:

1. determining the insurance premiums for compulsory motor liability insurance, based on the partial liberalization of their calculation. Thus, it is proposed that insurance premiums be set by insurers based on their own statistics, taking into account country-wide unique methodology approved by the supervisory authority;

2. regulating the way of establishing the real damage incurred as a result of motor vehicle accidents. This way is based on the assessment of the damage value, in case of the replacement of spare parts using the actual prices charged by specialized units;

3. regulating the external financial guarantee required to NBMIM by the Council of Bureaux on the International Green Card System. The draft law includes a separate article which shall amend the Law on compulsory motor insurance of civil liability no. 414-XVI of 22.12.2006 with the art. 351 which will stipulate that the external financial guarantee is set out by the National Bureau at the request and in the amount required by the Council of Bureaux. The insurer contribution to the external financial guarantee is calculated as the ratio between the amount of the guarantee to the number of insurers licensed to practice compulsory internal and external motor liability insurance.

The above mentioned draft law has been approved in the first reading in the Parliamentary session of the Republic of Moldova of 05.11.2015 and is awaiting for the final approval.In order to improve and consolidate the NCFM supervisory powers in the field of capital market, Polish experts have examined and proposed amendments to the new Regulation on Capital Market Abuse which partially transposes the Regulation (EU) No 596/2014 of the European Parliament and of the Council of 16.04.2014. The new regulation establishes the regulatory framework for identifying capital market abuse, including in reference to capital market insider trading, unauthorized disclosure of privileged information and to market manipulation, along with measures for the prevention and avoidance of the market abuse aimed at providing for the integrity of the capital market and for the consolidation of protection and trust of investors in this market.

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Project Assumptions

In the reporting quarter the Twinning Project has provided the first input to achieving the fulfilment of commitments of the Republic of Moldova stipulated in the former Partnership and Cooperation Agreement between the European Union and the Republic of Moldova, repealed and replaced by the Association Agreement between the European Union and the European Atomic Energy Community and their Member States, of the one part, and the Republic of Moldova, which is currently in force.

In particular, the Twinning Project has as main objective to contribute to the process of transition from compliance-based supervision to the establishment of the risk-based supervision for the three sectors of the non-banking financial market.

The undertaken activities will be subsequently continued and developed within the relevant project activities in line with the Twinning Work Plan.

2B - ACHIEVEMENT OF MANDATORY RESULTS

Results and indicators of achievement (as in Longframe)

State of achievement/ problems encountered

Component 1 – Strengthening operational and institutional capacities of the NCFM.

Indicator of achievement (copied from longframe) Strengthening operational

and institutional capacities of the NCFM accomplished.

Internal procedures/manuals/rules developed in line with the EU best practice.

Within the reporting period the first project activities were performed in line with the work plan:

Activity 0.1 Project inception and kick – off meeting

Benchmarks: The kick–off conference organized in the second month of the project.Relevant counterparts and stakeholders informed about the goals of the project.

State of achievement:Activity successfully completed and the result achieved. The kick – off conference was organized jointly by the Polish and Moldovan partners, in Palatul Republicii in Chisinau on 30 October 2015. The purpose of providing a first official contact to all stakeholders involved in the project and presenting the project to the media and the public at large was successfully achieved. In order to guarantee wide public information about the start of the project, the meeting was concluded with a press conference and a press release was prepared.The nature of this meeting was operational and was attended by representatives of the European Union

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Delegation to the Republic of Moldova, the Embassy of the Republic of Poland in Chisinau, the high level representatives of the Parliament and the Government of the Republic of Moldova, the NCFM, the KNF as well as key Moldovan financial market participants i.e. the National Bank of Moldova, Moldova Stock Exchange, National Securities Depository of Moldova, investment firms, independent registrars and insurance companies as well as central savings and loan associations. Representatives of 3 media companies provided press coverage of the meeting. The kick-off meeting gave the participants the opportunity to acquire detailed information about the project objectives, its purposes and implementation plan. The project summary, containing key information on the project, its stakeholders and the project purpose was distributed among the participants.

Activity 1.1. Development of conceptual framework of Risk-Based Supervision on non-banking financial market.

The Activity 1.1 was carried out within the first expert mission.

Benchmarks: Recommendations on the steps to be taken in order to establish the risk based supervision of insurance sector in the NCFM developed.

State of achievement:Activity successfully completed and the result achieved.Interactive workshop on risk-based supervision establishment delivered. During the workshop the STE from the KNF presented practical aspects associated with the risk-based supervision from the perspective of the KNF as well as other EU Member States. An analysis of two complex case-studies, followed by discussions between the KNF and NCFM experts, was conducted during the workshop. The review of the current legislation and practices regarding risk-based supervision of insurance market was completed as well. Based on that review and discussions with the NCFM experts the recommendations on the steps to be taken in order to establish the risk-based supervision of the insurance sector in the NCFM were developed and included in

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the elaborated Review report.

Activity 1.6. Strengthening the capacities against market abuse, manipulations and insider transactions (part 1).

Benchmarks: Review of the NCFM’s capacity in the field of combating market abuse in the capital market (market manipulation and insider trading) and workshops for the NCFM and market participants performed.

State of achievement:Activity successfully completed and the result achieved.Workshop on combating market abuse in the capital market (market manipulation and insider trading) for the NCFM and market participants was delivered. During the workshop STEs from the KNF presented practical aspects associated with the inside information, market manipulation and market abuse from the perspective of the relevant EU rules. The review of NCFM’s capacity in the field of combating market abuse in the capital market (market manipulation and insider trading) is completed. The Polish experts have verified the NCFM powers envisaged in the Moldovan law and the way the provisions on market abuse are constructed as well as how the legal framework and the NCFM capacity in the end influence the process of effective combat of market abuse.The Polish experts developed the review report with gap analysis in regard to NCFM’s capacity in the field of combating market abuse, including such aspects as inside information definitions, publication of information by the issuers, delay of publication of inside information, unlawful/unauthorised disclosure of inside information, legitimate behaviour, market soundings, accepted market practices, insider lists, transactions implemented by the management personnel, suspicious transactions and orders report. Relevant recommendations were included in this report as well.

Component 2 – Capital Market and Investment Funds.

Indicator of achievement (copied from logframe)

Strengthening operational and institutional capacities of

Within the reporting period there were no activities foreseen to be implemented within the component 2.

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NCFM to supervise and regulate capital market and investment funds sector accomplished.

Component 3 – Insurance Companies.

Indicator of achievement (copied from logframe)

Strengthening operational and institutional capacities of NCFM to supervise and regulate insurance companies sector accomplished.

Within the reporting period there were no activities foreseen to be implemented within the Component 3.

Component 4 – Savings and Credit Associations (Credit Unions) and Pension Funds.

Indicator of achievement (copied from logframe)

Strengthening operational and institutional capacities of the NCFM to supervise and regulate savings and credit associations (credit unions) and pension funds sector accomplished.

Within the reporting period there were no activities foreseen to be implemented within the Component 4.

2C. ACTIVITIES IN THE REPORTING PERIOD

The Twinning contract no ENI/2015/363-321 was notified on August 12, 2015. The implementation of the Twinning project Development and consolidation of the National Commission for Financial Markets’ operational and institutional capacities in the field of prudential regulation and supervision started on September 01, 2015 with the arrival of the MS RTA to Moldova.

The works in the inception period were focused on:1) Preparation of the RTA secondment to Moldova - Chisinau;2) Performance of the tender procedures in regard to air tickets, health and

accident insurance for the RTA, lease an apartment for the RTA as well as the selection of the RTA Assistant;

3) Performance of the tender procedures in regard to production of visibility products to be used in the project such as roll-ups, pens, notebooks, folders, business cards and pendrives;

4) Establishing the RTA in Chisinau (set up of the RTA office at the premises of NCFM, getting familiarized with the relevant institutions in Chisinau i.e.

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representatives of the Delegation of the European Union to Moldova, Embassy of the Republic of Poland in Chisinau.

After arriving to Chisinau, the RTA held a series of meetings with representatives of the Delegation of the European Union to Moldova and Embassy of the Republic of Poland in Chisinau. The RTA also met with the Adviser on Banking Sector to the Prime Minister‘s Office of the Republic of Moldova. The meetings were intended to make contact for further cooperation and to provide overview of general objectives of the project.

During the reporting period the following project activities took place:

Activity 0.1 Project inception and kick-off meetingNames of MS experts who delivered the activity:

1. Lesław Gajek – Vice-Chairman of the KNF,2. Damian Jaworski – MS Project Leader,3. Joanna Lipowczan – MS Project Manager,4. Grzegorz Wąsik – MS RTA.

Experts from the BC who participated in the kick-off meeting and their departments of origin:The Deputy Chairman and Deputy Chairwoman of the NCFM and 12 experts, including high and medium level representatives of the Beneficiary administration (Council of Administration, General Executive Division, Foreign Relations and Development Division, Division of Service stability and monitoring activities for preventing and combating money laundering and terrorist financing, General Division of Legal Assistance, General Division of Securities Supervision, Issuers Monitoring Division, General Division of Insurance Supervision, General Division of Collective Placements and Micro-financing).

Other participants of the kick-off meeting:Representatives of the European Union Delegation to the Republic of Moldova, the Embassy of the Republic of Poland to the Republic of Moldova, the Moldovan Parliament and the Moldovan Government, the National Bank of Moldova, the representatives of international organizations that are present in Moldova (i.e. EU-UNDP, World Bank, Consolidated Unit for Implementation of IFAD Programmes) as well as key Moldovan non-banking financial market participants i.e. National Securities Depository, Moldova Stock Exchange, National Bureau of Motor Insurers, Competition Council, Actuarial Association of Moldova, CSCA “Credit Union”. Representatives of Moldovan investment firms and insurance companies also took part in that event.

In the second month of the work plan implementation the kick-off event took place. The kick – off meeting was organized jointly by the Polish and Moldovan partners, in Palatul Republicii, in Chisinau on 30 October 2015.

The objective of providing a first official contact to all stakeholders involved in the project and presenting the project to the media and the public at large was successfully achieved.In order to make sure that the information about the start of the

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project was widely available to the public, the meeting was concluded with a press conference and a press release.

The nature of this meeting was operational and attended by the Head of Operations at the European Union Delegation to the Republic of Moldova, Ambassador of the Republic of Poland in Chisinau, Deputy Chairman of the Polish Financial Supervision Authority, Deputy Chairman of the National Commission for Financial Markets, Deputy Prime Minister and Minister of Economy of the Republic of Moldova, Chairman of the Parliamentary Commission for Economy, Budget and Finance, who gave speeches regarding main subject of the twinning project and financial markets in Moldova and in Poland.

In addition, presentation about project implementation strategy was presented by the MS Project Leader.

Journalists from 3 media companies (1 TV channel – MBC; 1 newspaper – Capital Market; 1 press agency – Infotag,) also attended the kick-off meeting. The kick-off meeting gave the participants the opportunity to receive detailed information about the project objectives, its purpose and implementation plan. The project summary, both in English and Romanian, containing key information about the project and its purpose was distributed among the participants of the conference.

Duration of the activity: 30 October 2015.

The Attendance List of participants of kick – off meeting (activity 0.1), the Press release about the Twinning Project and the Information – conference materials associated with activity 0.1 are attached in Annex no 1.

Component 1 Strengthening operational and institutional capacities of the NCFM.

Activity 1.1 Development of conceptual framework of Risk Based Supervision on non-banking financial market.

Activity 1.1 was carried out within the first expert mission.

Name of MS expert who delivered the activity: 1. Iwona Szczęsna (Key Short Term Expert) – Head of Unit, Analyses and

International Cooperation Department, Polish Financial Supervision Authority.

Experts from the BC who participated in the activity 1.1 and their departments of origin.The expert meetings organized within the framework of Activity 1.1 were attended by 15 NCFM employees in total. The BC experts were from the Foreign Relations and Development Division of NCFM and General Division of Insurance Supervision of NCFM (i.e. Insurance Regulation and Authorization Division, Insurance Control Division, Insurance Regulation and Authorization Division and Monitoring, Statistics and Actuarial Division).

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Duration of the activity: 19th – 21st October 2015.

The Activity fiche (No 1) for activity 1.1, the Evaluation sheet of the activity 1.1, the Review report with recommendations from the perspective of establishing risk-based supervision for insurance market resulting from activity 1.1, the Workshop materials for supervisory use resulting from activity 1.1, the Attendance list regarding activity 1.1 are attached in Annex no 2.

Activity 1.6 Strengthening the capacities against market abuse, manipulations and insider transactions (part 1).

Names of MS experts who delivered the activity: 1. Marcin Pachucki (Key Short Term Expert) – Deputy Director, Legal

Department, Polish Financial Supervision Authority. 2. Joanna Banach (Short Term Expert) – Specialist, Legal Department, Polish

Financial Supervision Authority. 3. Paweł Jaroszewicz (Short Term Expert) – Head of Unit, Legal Department,

Polish Financial Supervision Authority.

Experts from the BC who participated in the activity 1.6 and their departments of origin.The expert meetings organized within the framework of Activity 1.6 were attended by 39 BC experts in total, including 15 NCFM employees and 24 representatives from the Moldovan capital market. The NCFM experts were from the General Division of Securities Market Supervision, Legal Department and Division of Monitoring Issuers. In addition 2 representatives of the Moldova Stock Exchange, 2 employees of the National Securities Depository, 13 representatives of investment firms operating in the Moldovan capital market and 7 representatives of independent registers participated in this activity.

Duration of the activity: 2nd – 6th November 2015.

The Activity fiche (No 6) for Activity 1.6, the Evaluation sheet of Activity 1.6, the Review report with gap analysis resulting from Activity 1.6, the Workshop materials for supervisory use resulting from Activity 1.6, the Attendance list regarding activity 1.6 are attached in Annex no 3.

2D. TIMING AND DELAYS

Adherence to time schedule

Activity/action Planned X Activity/action Performed

Activity/action Delayed by more than 3 months

Year 2015 2016 2017

Mont I X X X I I II I V V V VI I X X X I II II I V V V VI

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h X I II I I V I II II X I II I V I II II

Project Month

1 2 3 4 5 6 7 8 9 10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

Component 1

Activity 0.1

X

Activity 0.2

Activity 1.1

X

Activity 1.2

Activity 1.3

Activity 1.4

Activity 1.5

Activity 1.6

X

Activity 1.7

Activity 1.8

Activity 1.9

Activity 1.10

Activity 1.11

Activity

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1.12

Activity 1.13

Activity 1.14

Activity 1.15

Activity 1.16

Activity 1.17

Component 2

Activity 2.1

Activity 2.2

Activity 2.3

Activity 2.4

Activity 2.5

Activity 2.6

Activity 2.7

Activity 2.8

Activity 2.9

Activity

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2.10

Activity 2.11

Activity 2.12

Activity 2.13

Activity 2.14

Activity 2.15

Activity 2.16

Activity 2.17

Activity 2.18

Activity 2.19

Activity 2.20

Activity 2.21

Activity 2.22

Activity

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2.23

Activity 2.24

Component 3

Activity 3.1

Activity 3.2

Activity 3.3

Activity 3.4

Activity 3.5

Activity 3.6

Activity 3.7

Activity 3.8

Activity 3.9

Activity 3.10

Activity 3.11

Activity 3.12

Activity 3.13

Component 4

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Activity 4.1

Activity 4.2

Activity 4.3

Activity 4.4

Activity 4.5

Activity 4.6

Activity 4.7

Activity 4.8

Recuperation of delays At this stage of Project implementation the timing of three experts’ missions has been changed within the same QR period depending on the availability of experts both from the KNF and NCFM. Activities 1.5 and 1.6 have been changed from December 2015 to November 2015. The activity 1.2 has been postponed from November 2015 to December 2015.  All above mentioned delays and changes in the time schedule did not impact the implementation of the Project and achieving of mandatory results, and they were discussed and approved by the PLs in order to fulfil the Project requirements and timeframes.   2E. ASSESSMENT  Overall Assessment of progress The project and the implementation of activities within the first project quarter went smoothly and timely.The project is being implemented in close cooperation between the KNF and the NCFM on a daily basis. The first activities within component 1 were provided and their planned mandatory results were achieved.Subsequent activities within component 1 are planned to be implemented in the next quarters. 

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In general, the technical and substantive problems arising during the project implementation are resolved quickly and efficiently. At this stage of the project implementation, there is no risk that future activities will not be completed or that they will be delayed for more than three months.

IssuesProject ManagementTo ensure and facilitate effective implementation of project activities the project schedule for the first 4 months (until the end of 2015) was bilaterally consulted and agreed, taking into account the current needs of the NCFM and availability of dedicated experts both on the KNF and NCFM side as well as public holidays in 2015 both in Moldova and Poland.

The preparation for the first Project Steering Committee (PSC) meeting scheduled for the fourth month of project implementation was initiated.

Visibility – overview of the progress in the Communication and Visibility Plan implementation

The Communication and Visibility Plan was elaborated in compliance with the Communication and Visibility Manual for Union External Actions laid down and published by the European Commission and upon being bilaterally agreed between the twin partners approved within the “no objection” feedback from the EU Delegation, received on 29 September 2015.

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