Question ID: 3468
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: 215(1)(f)
Status: Rejected
Date of submission: 26 Nov 2025
Question
Can guarantees on mortgage loans be recognized in the calculation of the Basic Solvency Capital Requirements if such guarantee conveys an own risk > 0 for the mortgage originator? e.g. 90% guarantee and 10% own risk.
Background of the question
Article 215(f) indicates that "the guarantee fully covers all types of regular payments the obligor is expected to make in respect of the claim.". It is not clear if by "fully" it is meant all types of regular payments, or all the mortgage loan amount due.
EIOPA answer
This question has been rejected because the question is not sufficiently clear, which creates uncertainty for which an explanation is merited regarding their practical implementation or application.