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European Insurance and Occupational Pensions Authority
 

1571

Q&A

Question ID: 1571

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

Status: Final

Date of submission: 26 Jun 2018

Question

We are about to invest in a mutual fund which invest on life insurance policies. This fund make its yield from buying policies from third parties in the US at a discount and they get the right from the policy holder to recieve the payment in the future.

EIOPA answer

The question does not provide enough information to provide a conclusive answer. The treatment for this type of product has to be decided on a case by case basis.  
Relevant aspects to consider in this decision include but are not necessarily limited to:
·       What is the exposure to biometrical risks?
·       Has the look-through approach to be applied to the investment?
·       What is the degree of certainty regarding level and timing of payments?
A possible result of the assessment could be that the investment has to be included in the calculation of the capital requirement for type 2 equities which include
·       Alternative investments.
·       All assets other not covered in the interest rate risk, property risk or spread risk sub-module
·       Assets and indirect exposures referred to in Article 84(1) and (2) of Commission Delegated Regulation (EU) 2015/35 where a look-through approach is not possible and the insurance or reinsurance undertaking does not make use of the provisions in Article 84(3).