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European Insurance and Occupational Pensions Authority

2286

Q&A

Question ID: 2286

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: N/A

Template: S.26.01

Status: Final

Date of submission: 07 May 2021

Question

we have one question related to the calculation of SCR_spread within market risk module for non-EEA companies (under Solvency II for Group purposes), when the discounting curve used to calculate liabilities is constructed from local government bonds. In the case of an EEA country, local bonds in local currency are exempt from the risk of credit spread (example Croatia or Poland) but what about when you have a undertaking that is based in a country other than EEA where local bonds in local currency are not exempt from the risk of credit spread under SII? Our problem is that when we calculate SCR_spread for non-EEA on the assets side of investment (local government bonds) we calculate the shock for the risk of credit spread (non-EEA local government bonds are not risk-free), but on the liabilities side we do not do so (although they are valued with exactly the same curve as assets – discount curve from local government bonds). Would it be correct to also calculate the shock on liabilities similar to shock under interest-rate submodule (we could use characteristics of an UP shock (from IRR) in credit spread submodule)? Is there some information how a (re)insurance company in EEA (under S2 regulation) value/calculate this in a subsidiary based in Russia, for example (or some other non-EEA country for which EIOPA calculates a discount curve from local government bonds (BR, CL, CO, MY, TW, TH, TR))? Do they apply a shock on liabilities, or they do not take this into account in the calculation of SCR_spread?

EIOPA answer

The determination of the capital requirement for spread risk should not include any change in the basic risk-free interest rates used to discount liabilities.
Article 44(2) of the Commission Delegated Regulation (EU) 2015/35 specifies that the rates of government bonds are adjusted for credit risk in order to derive the basic risk-free interest rates. Therefore, any change in this credit risk component should not be assumed to feed through into the risk-free rates.