Skip to main content
Logo
European Insurance and Occupational Pensions Authority
 

1438

Q&A

Question ID: 1438

Regulation Reference: (EU) No 2015/35 - supplementing Dir 2009/138/EC - taking up & pursuit of the business of Insurance and Reinsurance (SII)

Article: 4

Status: Final

Date of submission: 28 Nov 2017

Question

Regarding Artice 4 Paragraph V 2nd sentence: "Where the own internal credit assessment generates a lower capital requirement than the one generated by the credit assessments available from nominated ECAIs, then the own internal credit assessment shall not be taken into account for the purposes of this Regulation."
Does paragraph 5 only apply to insurance undertakings which calculate the SCR according to the standard formula or does it apply to insurance undertakings which use an approved internal model as well?

EIOPA answer

The context of article 4 of the Delegated Regulation indicates that article 4(5) only applies to the standard formula. Article 4 is in section 2 (“External credit assessments”) of chapter 1, introduced by article 3, which sets the context referring to article 109a on the use of own credit assessments in the standard formula. In addition, article 4 paragraphs 1, 2 and 6 explicitly refer to the standard formula. The first sentence of article 4 (5) also applies to the standard formula by referring to the seven credit quality steps introduced in article 3.
Furthermore, recital (4) defines the motivation for setting up the rules on own credit quality assessment: the recital clearly defines the motivation of a requirement as given by article 4(5) and only addresses the standard formula with the intention to avoid biased estimations of credit risk.
Unlike the Standard Formula, internal models and thus credit modelling are subject to approval, and therefore the methods to calculate the Solvency Capital Requirement using own credit quality assessments are under supervisory control. The recital should be read in this context.