Question ID: 2823
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Risk concentration
Template: S.37.01
Status: Final
Date of submission: 10 Oct 2023
Question
Could you elaborate "Insurance policies" in QRT S.37.01.
1. What kind of insurance risk concentrations should we include and how. Should we sum all the risks and policies together from the same counterparty even if the risks are not in the same risk concentration, if you consider two buildings far away from each other.
2. What if you should report distinct risk concentrations (like two buildings far away each other) separately to the same counterparty. One Counterparty has taken many insurance policies to many different locations. Should we report many lines to this same counterparty per insurance policy and also by risk concentration? Or just sum all insurance sums together which is not relevant if you want to report risk concentrations? Or should you take a maximum possible sum insured for the policies?
3. There was a comment that risks where the counterparty is a individual person are not to be reported, but what if company has taken workers compensation or MTPL insurance. So the counterparty is a company, but how one would calculate risk concentration for those insurance policies. It seems like the counterparty is not relevant information regarding the insurance concentrations, one would think that risk concentrations should be reported by location or risk concentration, and not by counterparty. Also can you sum credit risks and insurance risks together to same counterparty as it's clearly different risk.
EIOPA answer
1. EIOPA confirms that the risk and polices are summed together for the same counterparty.
2. The reporting is assumed to be by counterparty so the risk concentration should be reported in the same line towards the same counterparty. This should be the sum of all sum insured, while considering limits regarding the exposure of the insurer if applicable.
3. Natural persons are in the scope, but not likely to be above the threshold. If the counterparty is a company the exposure will depend on the policy contract with this company – undertakings could add an explanation regarding this contract in the narrative reporting.