The validation rules require the value at {S.28.01, r0230,c0050} to be greater than or equal to the TP as a whole and BEL (net of reinsurance) from S.12.01, less the transitional amounts on TP as a whole and BEL. This is inconsistent with Guideline 9 from the Guidelines on the implementation of the long-term guarantee measures, which requires that the value used in the MCR calculation should be the TP before the transitional minus the maximum of the risk margin and the amount of the transitional deduction. Where the transitional on the best estimate liability is positive(increases the best estimate liability), the risk margin will be greater than the transitional amount, and the value used in the MCR calculation is less than the S.12.01 side of the validation formula.

Do we need to deviate from the guidelines and build up the TP measures in the MCR calculation from the TP as a whole and best estimate figures on S.12.01 as suggested by the validation formula, instead of starting with technical provisions and deducting risk margin? Or should we use the formula suggested by the Guidelines, in which case the current validation rules would block the QRT submission?