Question ID: 2677
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Reporting Templates
Article: Template S.26.13
Status: Final
Date of submission: 07 Jun 2023
Question
Template code: S.26.13 Template title: Internal model - Non-life & Health NSLT Underwriting risk
We would like to enquire on information to be entered for all perils. Is it in general the highest sum insurred out of all the perils or something else? As we may have different Sum Insured (e.g. for Earthquake, Flood, Windstorm etc) it is not clear to us all perils Sum Insured is to be interpreted. We see two options:
Option 1: Sum all Sum Insured across different perils (which seems exaggerated to us)
Option 2: Report the highest Sum Insured out of all perils like we did for NLCS study
Background of the question
For cells C0420/R1960-1990 (Total Sum Insured – Reinsurance) is in the document “2450_ITS_reporting_consolidated_AnnexII_solo instructions_S.26.02_to_S.36.05.docx”, page 100 written: “The insurance or reinsurance undertaking is expected to split their total sum insured for reinsurance by geographical region. Geographical regions to be used are Europe, North America and Rest of World. Any unallocated premium should be put in the Unallocated bucket.”
EIOPA answer
Contracts may have differing but overlapping coverage. In cases where the highest sum insured for a combination of perils is requested please remove the overlap and please report the highest Sum Insured out of all perils similar to the NLCS study (option 2) for cells C0420/R1960-1990.