Question ID: 1416
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Status: Final
Date of submission: 08 Dec 2017
Question
If possible please could you clarify the response, as we are still unclear how this would work where overall the Group operates under a Partial Internal Model. The assets of the Group comprise of those for firms on a full internal model and one firm on standard formula. For the same asset we have an ECAI for those firms on full Internal Model and a different ECAI for the firm on Standard Formula.
We are still not clear what ECAI would be reported for Group and do not understand how the ECAI can be unique as in this example there would be two? We have also considered the method used for the calculation of the Group SCR but
we are still unclear as this calculation is a Partial Internal Model and also therefore has some firms as full Internal Model SCR and one firm on Standard formula SCR.
We would be grateful if you could please provide further clarity.
EIOPA answer
In the case described in fact there could be more than one ECAI at group level. The current design of the template does not allow it so please in this case report the most representative ECAI at group level, considering the amounts held by the undertakings under the PIM and under the SF.
A revision of the template will be considered in future to accommodate this situation.