Question ID: 1712
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35, 226
Template: S.23.01
Status: Final
Date of submission: 12 Dec 2018
Question
According to article 226 (1) of Directive 2009/138/EC an insurance holding company shall be taken into account when calculating the group solvency, meaning that a notional SCR has to be calculated for it.
In QRT S.34.01 there is also a column for the notional/sectoral MCR of an insurance company or OFS in addition to the column for notional SCR.
Is our understanding correct that an insurance holding company also needs to be considered when calculating the Minimum consolidated Group SCR (R0610/C0010 in S.23.01.04)?
Otherwise the Ratio of Eligible own funds to Minimum Consolidated Group SCR (R0650/C0010 in S.23.01) would be calculated with the insurance holding company in the numerator (own funds) but without the insurance holding company in the denominator (MCR), which seems inconsistent.
EIOPA answer
The notional MCR of the insurance holding company (IHC) is not required for the calculation of the group Minimum consolidated Group SCR.
Therefore the ratio of Eligible own funds to Minimum Consolidated Group SCR would be calculated taking into account the insurance holding company in the numerator (group own funds) but without the contribution of the insurance holding company in the denominator (Minimum consolidate Group SCR).
A reference to such treatment of the IHC could be found in the Final Report on Public Consultation No. 14/036 on Guidelines on group solvency, in the Explanatory text below Guideline 21.