Question ID: 16
Regulation Reference: Guidelines on system of governance
Article: 44
Status: Final
Date of submission: 19 Dec 2013
Question
Article 44(2)(d) of Directive 2009/138/EC refers to both ‘liquidity and concentration risk management.
Nevertheless EIOPA preparatory guidelines only refer to liquidity risk management
Is it necessary to cover concentration risk management during the preparatory phase of Solvency II?
EIOPA answer
It is right that the preparatory Guidelines only mention liquidity risk with regard to Article 44(2)(d) of Directive 2009/138/EC, see Guideline 24.
However it is anticipated by EIOPA that during the preparatory phase National Competent Authorities and undertakings are preparing for the implementation of all areas covered by Solvency II Directive and not only those covered by the
preparatory Guidelines.
With regard to risk management EIOPA underlines that undertakings need to have all sub policies in place at the start of Solvency II which implies that they should use the preparatory phase to draft all sub policies and implement them step by step during this phase.
Please refer to the section ‘Feedback Statement’ in EIOPA Final Report on Public Consultation No. 13/008 on the Proposal for Guidelines on the System of Governance; https://eiopa.europa.eu/fileadmin/tx_dam/files/consultations/consultationpapers/CP08-13/EIOPA-13-413_Final_Report_on_CP8.pdf