The company addressed EIOPA with a question related to the possibility of excluding loans approved on the basis of life insurance policies from the concentration market risk sub-module (Question ID: 2549). EIOPA answered: „It is assumed that in the example provided the policyholder loan is a loan as referred to in Article 176 of Commission Delegated Regulation (EU) 2015/35 (DR). This loan should be taken into account in the calculation of the market risk concentration sub-module. In order to take into account in that calculation that the lender can cancel the insurance obligation towards the policyholder, consideration should be given to all relevant contractual aspects and potential restrictions, especially regarding enforceability and timing of the cancelation. These considerations should include in accordance with Article 83(2)(a) DR the requirements on management actions set out in Article 23 DR. Following the scenario in which there is an instantaneous decrease in the value of the loan, the market risk concentration sub-module should take into account any change in value of the obligation to the policyholder so long as those requirements on future management actions are complied with in relation to the cancellation of that obligation. Consideration should be given in particular to the enforceability of the cancellation of the obligation towards the borrower, for example, whether the cancellation will be accepted by the liquidator in situations where that is relevant.“ The company would like to emphasize that when asking the question, it already took into account all relevant contractual aspects and potential restrictions, as well as requirements related to future management actions. Also, all possible scenarios of changes in value and enforceability were taken into account, and the Company's conclusion is that, considering all the above, no scenario of loss or loss of own funds is possible, that is, the condition stipulated by the definition of concentration risk specified in Art. 183, paragraph 2. Delegated Regulation 2015/35. and Art. 13, item 35 of Directive 2009/138 is not fulfilled. The facts established in this way are also the Company's motive for the additional inquiry following the answer EIOPA provided. The company once again points out that the loan approved on the basis of life insurance policies is essentially identical to the Lombard loan, which does not produce a capital requirement for banking institutions. We believe that loans approved on the basis of life insurance policies should have the same treatment as Lombard loans in credit institutions in order to guarantee equal conditions of market competition, all in accordance with Recital 3 of the Delegated Regulation of the EU Commission 2019/981, which states as follows: „In order to ensure a level playing field between economic operators active in the insurance sector and economic operators active in other financial sectors, some of the provisions applicable to insurance and reinsurance undertakings should be aligned with the provisions applicable to credit and financial institutions, to the extent that such an alignment is commensurate with their different business models.“ Assuming that the Company has taken into account all the necessary factors and that even then there is no possibility of loss or loss of own funds, is it possible to exclude the loans in question from the concentration market risk sub-module considering that the risk does not exist?