Alan Reed has posted his response to the HMT consultation on Matching Adjustment on LinkedIn here. The key paragraph is this:
The proposals suggested in this section of my response address what I consider to be serious issues. To the extent that the current MA regime is allowing firms to claim more MA benefit than is justified by the inherent features of their assets and their portfolio management strategies, as a result of arbitraging weaknesses in the regime, then some MA portfolios must, as a direct result, be providing a lower level of long-term security for their policyholders/beneficiaries than the MA regime intended. Further, potentially, one or more MAPs may plausibly become unsustainable as a result of too much extraction of value early by advisors and shareholders, leaving insufficient to allow the MAP to continue to operate sustainably in compliance with the MA regime. Such an outcome could reasonably be seen by society as a failure of the industry, regulation and associated professions which a society that has already tolerated Equitable Life and the Great Financial Crisis may, reasonably, not be accepted lightly by society.
I commend Alan for this, and I believe it is the first time a qualified, professional actuary has commented on MA in such terms. Let there be many more.