Question ID: 3603
Regulation Reference: (EU) No 2015/35 - supplementing Dir 2009/138/EC - taking up & pursuit of the business of Insurance and Reinsurance (SII)
Article: 192(4a)
Status: Final
Date of submission: 24 Jun 2026
Question
The question is related to the SII review change in COMMISSION DELEGATED REGULATION(EU) 2026/269, Article 192 4a.
The calculation of LGD for defaulted and forborne loans is LGD = max (Loan – Recoverables; 36 % × Loan) where:
(a)Loan denotes the value of the mortgage loan determined in accordance with Article 75 of Directive 2009/138/EC;
Why does "Loan denotes the value of the mortgage loan"?
Why is mortgage loan mentioned here? Is it a mistake?
Background of the question
SII Review
EIOPA answer
In the formula set out in Article 192(4a) of Commission Delegated Regulation (EU) 2015/35, Loan should be understood to denote the value of the defaulted and forborne loan.
We expect that the reference to “mortgage loan” will be replaced by a reference to “loan” in future revisions of the Delegated Regulation.