Question ID: 1685
Regulation Reference: (EU) No 2015/35 - supplementing Dir 2009/138/EC - taking up & pursuit of the business of Insurance and Reinsurance (SII)
Article: 176
Status: Final
Date of submission: 30 Nov 2018
Question
Intercompany loans should be stressed within the market risk module.
Where intercompany loans are repayable on demand, that is the loan does not have a defined term, is it still appropriate to stress within the market risk module? For example, where two companies (Company A and Company B) participate in zero balancing arrangments ("overnight pools" or "pooling arrangements") such that intercompany loans are established when funds are transfered from Company A's account to Company B's account, would it be more appropriate to treat the loan as "cash at bank" and stress the asset within the counterparty default risk module?
The argument is that, similar to cash at bank, this asset should be available on demand, unlike a loan asset which is usually not available on demand.
EIOPA answer
The described loan should be included in the calculation of the capital requirement for market risk including the calculation of the capital requirement for spread risk. In accordance with Article 176 (2) of Commission Delegated Regulation (EU) 2015/35 the minimum modified duration is 1.