Question ID: 2173
Regulation Reference: (EU) No 2015/35 - supplementing Dir 2009/138/EC - taking up & pursuit of the business of Insurance and Reinsurance (SII)
Topic: Solvency Capital Requirement (SCR)
Article: 142
Status: Final
Date of submission: 07 Aug 2020
Question
Under Life Lapse scenario Article 142, the stress should be the most onerous of the up/down/mass lapse scenario across all the policyholder options listed in paragraph 4. Please clarify that this means undertakings must assess the most onerous of up/down/mass changes to rates for all options listed under Article 1 paragraphs 14-16.
Background of the question
In practice there are mixed approaches across companies to calculating this stress and it is not clear that the impact of lapse, partial withdrawal, PUP, premium reduction, renew, extend, resume and increase are assessed for each policy.
EIOPA answer
For the up and down stresses, all options listed under Article 142 (4) of Commission Delegated Regulation (EU) 2015/35 (e.g. partial termination) should be taken into account in the scenario calculations, where a stress to the exercise rate of those options would result in an increase of technical provisions without the risk margin.
For the mass lapse stress, the undertaking shall base the calculation on the type of discontinuance which most negatively affects the basic own funds of the undertaking on a per policy basis. All possibilities for discontinuance set out in Article 1 (14) of Commission Delegated Regulation (EU) 2015/35 should be considered.
The calculation of the up, down and mass lapse stresses should be performed on a per policy basis, although Article 95a of Commission Delegated Regulation (EU) 2015/35 permits a simplification where Article 88 of Commission Delegated Regulation (EU) 2015/35 is complied with, so that the calculation can instead be performed on the basis of groups of policies, provided that the grouping complies with the requirements laid down in points (a), (b) and (c) of Article 35 of Commission Delegated Regulation (EU) 2015/35.