We would like to come back to question #2 in the document - "Answers to Guidelines on Financial stability",  published on 17.12.2015, and here to statement 4) on partial surrender.

What is the rationale behind considering each partial surrender as one surrender? A partial surrender does not decrease the number of contracts in force, so that considering a partial surrender in the same way as a total surrender does not seem to give an appropriate view on the impact of surrenders on the number of contracts in force. In addition, counting each partial surrender will lead to situations where one contract with several smaller partial surrenders will contribute several times to the lapse rate, although the number of contracts does not change. The German HGB regulation therefore does not consider numbers for partial surrender; volume however is measured. We suggest to not consider partial surrenders in the lapse rate by contracts, but only in the lapse rate by volume. Can you confirm that numbers of partial surrenders must indeed be considered in the lapse rate by contracts although the number of contracts does not change?

Are paid ups (Beitragsfreistellung) also supposed to be considered in the lapse rate by contracts? According to question #7 of the above mentioned document, volume effects are supposed to be considered if material. In our case, volume effects are small, but numbers may be relevant. Paid ups do not change the number of contracts in force; we therefore suggest to not consider them in the lapse rate by contracts.