Question ID: 79
Regulation Reference: Guidelines on submission of information to NCAs (Preparatory phase)
Article: 35
Template: S.26.04
Status: Final
Date of submission: 06 Jun 2014
Question
In relation to QRT S.26.04, we would like to ask for clarification about the Health catastrophe risk sub-module (cells A21-A23 and B21-B23):
During the Preparatory Phase, the health catastrophe risk sub-module distinguishes between Net and Gross capital requirement (including/excluding the loss-absorbing capacity of technical provisions).
In the Instruction of cell A21 (Gross SCR for Mass Accident (excluding the loss-absorbing capacity of technical provisions)) it is stated that the item should be equal to the item reported in cell A23 (Gross SCR for Mass Accident) of QRT S.27.01.
However, “Gross SCR for Mass Accident” in QRT S.27.01 relates to different concept (SCR for mass accident gross of risk mitigation.
Could you clarify the relation between Gross/Net SCR of loss-absorbing capacity of technical provisions and Gross/Net SCR of risk mitigation?
Additionally, could you please clarify definitions for cells A21, A22, A23, B21, B22 and B23 of QRT S.26.04 and their links to items of QRT S.27.01?
Currently, the link is only available for cells A21-A23 and, as explained above, the accurateness of these links is not clear.
EIOPA answer
There is in fact an inconsistency.
Template S.26.04 include SCR amount gross and net of loss-absorbing capacities of TP while template S.27.01 include SCR amounts for gross and net of risk-mitigation techniques but gross of loss-absorbing capacity of TP.
This means that the amounts reported in S.26.04 as ‘gross’ should be equal to the amounts reported in S.27.01 as ‘net’.