The view is that the assessment of the situation is to be done by the undertaking considering the legal situation. In some cases the instrument is impaired while in others there was already a legal write-off. In cases where there was a legal write-off the notional amount should be the new amount, after deduction of the write-off. The par amount and the Solvency II value will need to reflect the write-off as well, i.e. needs to be linked to the new notional amount.

We believe that when it is called a write-off, then it is definitive, if not, it is not a write-off but a valuation below the par or an impairment.