Question ID: 3652
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: 178(6)
Status: Rejected
Date of submission: 23 Sep 2026
Question
The article says that for not rated non-senior STS positions, it should be assumed that the credit quality step is 5 and use the table in paragraph 3. However, that table is for senior STS positions.
Would it not make more sense to use the table in paragraph 5 instead that is already for non-senior STS securitisations? Otherwise the not rated non-senior STS positions end having stress factors around non-senior STS positions with CQS 3 or lower.
EIOPA answer
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