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Article 188 of the SII Delegated Acts covers currency risk but only refers to different charges where currencies are pegged to the Euro. We are a US dollar functional currency entity and we are currently taking capital charges on currencies that are pegged to the USD which seems very punitive. For...

With reference to Article 135 & Annex XII and the risk factor of 40% applying to Miscellaneous Financial Loss we would be grateful for your help in relation to our query.We underwrite pet insurance business (mainly dog, cat and equine, majority being dog) which provides reimbursement of vet fees...

The definition of written premiums in this article is vague. Should written premiums be "The amount payable by the policy holder excluding insurance premium taxes for insurance or reinsurance cover written during the period whether such premiums relate in whole or in part to insurance or...

We kindly ask for your support in clarifying a specific issue related to the application of the Solvency II provisions regarding outsourcing in conjunction with the provisions of Regulation 21327/85 on the European Economic Group (EEIG).In the situation where two insurance companies, entities of a...

Paragraph 4 states 'Expenses shall be projected on the assumption that the undertaking will write new business in the future'.Could you please provide information on the application of this paragraph to entities that are closed to new business? For example, should the entity assume that they...

Could you please provide me with your opinion on the following issues regarding the simplifications introduced via Article 107:a) Does variable "Recoverables(i)" includes also receivables from counterparty i (i.e. amounts past due by reinsurers and linked to reinsurance business that are not...

Do government-guaranteed bonds issued in a currency different than the domestic currency of the guarantor get assigned a credit stress risk factor of 0%?

Could you please confirm that OFS should completely be excluded from the calculation of group market risk and counterparty default risk, meaning that neither the participation in an OFS nor the assets of an OFS should be included when calculating these risks for the purpose of Art. 336 a Delegated...

We would ask you to answer the following questions:- can a supervisory report of the own risk and solvency assessment carried out pursuant to the Article 304(1)(c) of the Commission Delegated Regulation (EU) 2015/35 (hereinafter: ORSA Report), which an insurance company submits to the supervisory...

The explanations of Art. 330 regarding the fungibility of own funds instruments leave some questions open in our view. Are there any concrete examples of fungible instruments or a detailed catalog of criteria for possible types of instruments?