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European Insurance and Occupational Pensions Authority
 

3603

Q&A

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.