Question ID: 150
Regulation Reference: Guidelines on submission of information to NCAs (Preparatory phase)
Article: 35
Template: S.27.01
Status: Final
Date of submission: 20 Aug 2014
Question
Regarding EIOPA's answer to question 29 (published in the website on 18.02.2014) and as a result of comparison with countries for health catastrophe risk,
How should be treated the SCR per country in the different health catastrophe risk sub-modules (i.e. mass accident, concentration and pandemic)?
a) In the technical specifications, mass accident is calculated for all countries "c" set out in Annex HUR3.
The rest of modules (concentration and pandemic) are calculated for all countries "c". Notice it says "countries "c"" with the same wording than used for mass accident but it does not say "set out in Annex HUR3".
What do you mean by country "c" within concentration and pandemic submodules? Does it refer to the same countries as Annex HUR3?
b) EIOPA's answer to question 29 states:"When the countries, either in or outside EEA or particular regions are not included in the regions identified, that means that the SCR calculation do not consider the exposure to risks in those areas (no capital charge for them). Those areas should not be reported."
I am aware your answer is linked to "Non-life catastrophe". However, Can your answer be extrapolated to health catastrophe?
c) In template "SCR-B3F-S.27.01", for concentration and pandemic risk, the LOG states in both cases: "for each of the countries identified in Items NA1 to NI31" (these are the countries in Annex HUR3).
Does it mean that country "c" only refers to Annex HUR3? Or Does it mean that the template is wrong?
EIOPA answer
a) In relation to the three modules identified (mass accident, concentration and pandemic) EIOPA confirms that, where the technical specifications do not refer to the first table of Annex HUR3, it is indeed not intended to limit the application of the health CAT modules to the countries listed in that table. Only the mass accident risk sub-module requires the ratio of persons affected (rs) on a per country basis as an external input, therefore the mass accident risk is limited to the countries listed in the annex. However, there is no need to limit the application of the accident concentration and pandemic risk to these countries. With regards to the accident concentration risk, the ratio of the persons who will receive benefits in a country (xe) is set out in the second table of annex HUR3, and the formula features no further ratio (rs). This is not required as the stress is applicable to the largest concentration risk only.
b) Regarding Q29, the answer should only be read for Natural Catastrophe Risk. Each sub-module have a specific calculation method.
c) In fact the template S.27.01 needs to be revised to reflect the approach referred above in a). This will be done for the TS.