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European Insurance and Occupational Pensions Authority

176

Q&A

Question ID: 176

Regulation Reference: Guidelines on submission of information to NCAs (Preparatory phase)

Article: 35

Template: S.26.01

Status: Final

Date of submission: 29 Oct 2015

Question

According to the EIOPA Final Report on Public Consultation No. 13/010 On the Proposal for Guidelines on Submission of Information to National Competent Authorities the Solvency Capital Requirement for Market risk has to be reported for the entity, the most material RFF and the remaining part.

The question regards the presentation of directional stresses and I would like to express my question through a numeric example as follows.

The example undertaking has the following structure:
RFF is the major material ring-fenced fund and the remaining part (RP) is also material.
The RFF has restricted own funds in that own funds exceed notional SCR.

Here are the SCR for Interest rate risk components for the above mentioned components of the undertaking:
Interest rate up RFF = +100
Interest rate down RFF = -100
Interest rate up RP = -90
Interest rate down RP = +50

What amount of SCR interest rate has to be reported for the "remaining part", RFF and undertaking in each of the forms S.26.01.b/l?

a)
S.26.01.b Interest rate 100
S.26.01.l RFF Interest rate 100
S.26.01.l RP Interest rate 0
b)
S.26.01.b Interest rate +50
S.26.01.l RFF Interest rate 0
S.26.01.l RP Interest rate 50
c)
S.26.01.b Interest rate +100
S.26.01.l RFF Interest rate +100
S.26.01.l RP Interest rate +50
d)
S.26.01.b Interest rate +50
S.26.01.l RFF Interest rate +100
S.26.01.l RP Interest rate +50

EIOPA answer

This answer is also relevant for the future Solvency II (not only prep. phase).

In the case of scenario-based calculations, recital 75 of the Delegated Regulation sates: “Where the calculation of the capital requirement for a risk module or sub-module of the Basic Solvency Capital Requirement is based on the impact of bidirectional scenarios on basic own funds, as in interest rate risk, currency risk or lapse risk, the insurance or reinsurance undertaking should determine which scenario most negatively affects the basic own funds of the insurance or reinsurance undertaking as a whole. This determination should, where relevant, take into account the effects of profit participation and the distribution of future discretionary benefits at the level of the ring-fenced fund. The scenario determined in this way should be the relevant scenario to calculate the notional Solvency Capital Requirement for each ring-fenced fund.”.

In this case the undertaking calculates both scenarios for all RFF/RP and then see the result for the up scenario/down scenario, assesses which one most negatively affects the undertaking and decides which one to apply. The relevant scenario has to be the same for all RFFs and the RP.

Regarding the cases bellow solutions c) and d) are wrong, since they consider different scenarios for the RFF and the RP. Between a) and b) the solution depends on the analysis of the scenario at entity level. If the example reflects all RFF of the undertaking the correct answer would be a).

Please note that templates S.26.s are not reported at entity level but only at RFF/MAP/remaining part.