I understand as per Article 180 2) that local authorities issuers benefit from a 0% SCR. Metropole de Lyon, as per Article 72 of the constitution, is considered as a local authority. Local authorities include "communes, départements, régions, collectivités à statut particulier and collectivités d'outre-mer" Metropole de Lyon is considered a "collectivité à statut particulier". There are 6 of them in total. However, Article 1 of Commission Implementing Regulation (EU) 2015/2011 specifies that only "communes, départements, régions" are eligible to 0% SCR for credit risk. Could you please let us know whether "collectivités à statut particulier", such as Metropole de Lyon could be eligible to 0% SCR? Or if we should rather have a litteral reading of the rule.
Background of the questionConfusion about SCR applicable to "collectivités à statut particulier"
The provision set out in article 180 2. of Solvency II COMMISSION DELEGATED REGULATION (EU) 2015/35 cannot be applied to entities which are not included in the list set out in Commission Implementing Regulation (EU) 2015/2011. French “collectivités à statut particulier” are currently not included in the Regulation and exposures to them can therefore not be treated as exposures to the French central government.
The shocks to be applied in this case are specified in article 180 paragraph 3a. of the Delegated Regulation 2015/35 providing that “Exposures in the form of bonds and loans to Member States' regional governments and local authorities not listed in Article 1 of Implementing Regulation (EU) 2015/2011 shall be assigned a risk factor stress i from the table in paragraph 3 corresponding to credit quality step 2.”