Question ID: 123
Regulation Reference: Guidelines on submission of information to NCAs (Preparatory phase)
Article: 35
Template: S.33.01
Status: Final
Date of submission: 05 Mar 2015
Question
In relation to cell A2 of QRT G04-S.34.01, we would to ask for a clarification on the following issue:
It is said that that “When the entities of other financial sectors form a group with a specific capital requirement, this consolidated capital requirement can be accepted instead of the list of each solo requirement.”
We understand that the scope of the QRT is for “other regulated and non-regulated entities”. In the case of a group formed by “other regulated and non-regulated entities” plus at least one entity entering in the scope of QRT G03-S.33.01, the figures reported in cells C1, D1 and E1 would contain additionally a consolidated SCR/MCR/Eligible own funds of an entity reported in G03. Do you confirm, that this kind of “overlap” between both QRT is acceptable?
EIOPA answer
In fact, in the Group Solvency Guidelines (Guideline 11), the group should consider using (the use is not automatic) the solvency requirements of such a group instead of the sum of the requirements of each individual undertaking when calculating the group solvency. However this possibility was intended to be used only by a subgroup composed mainly by undertakings from the other financial sectors (i.e. no related insurance undertakings).