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CEIOPS' Advice for Level 2 Implementing ... - EIOPA - Europa

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3.317 This simplification takes into account the maturity and the run-off pattern<br />

of the obligations net of reinsurance. However, it is based on the following<br />

simplified assumptions:<br />

• the length of the contracts is one year at the most, i.e. there is no<br />

premium and catastrophe risk after year 0 (non-life underwriting<br />

risks),<br />

• the average credit standing of reinsurers and SPVs remains the same<br />

over the years (counterparty default risk),<br />

• the modified duration is the same <strong>for</strong> obligations net and gross of<br />

reinsurance (operational risk, counterparty default risk).<br />

3.318 An undertaking that intends to use this simplification <strong>for</strong> one or several<br />

lines of business (or homogenous risk groups), should consider to what<br />

extend the assumptions referred to in para 3.317 are fulfilled <strong>for</strong> the<br />

line(s) of business in question. If some or all of these assumptions do not<br />

hold, the undertaking should carry out (at least) a qualitative assessment<br />

of how material the deviation from the assumptions is. If the impact of the<br />

deviation is not material compared to the risk margin as a whole, then the<br />

simplification can be used. Otherwise the undertaking should either adjust<br />

the <strong>for</strong>mula appropriately or be encouraged to use a more sophisticated<br />

calculation or method.<br />

3.319 For example, if there is a notable difference in the modified durations of<br />

the obligations gross of reinsurance, net of reinsurance and reinsurers'<br />

share of the obligations, then the <strong>for</strong>mula should be adjusted such that the<br />

modified duration used in OPRU,lob,>0 is based on obligations gross of<br />

reinsurance and the modified duration used in CDRU,lob,>0 is based on<br />

reinsurers’ share of the obligations.<br />

3.320 If there arises premium risk or catastrophe risk after the first year then an<br />

additional risk charge that represents this risk can be added to the<br />

<strong>for</strong>mula.<br />

3.321 In the calculations sketched in para 3.315 and 3.316 it has been tacitly<br />

assumed that with respect to the present (simplified) approach the<br />

unavoidable market risk can be disregarded <strong>for</strong> the lines of business within<br />

non-life insurance. If this assumption does not hold – and the unavoidable<br />

market risk is believed to have a substantial impact on the SCRcalculations<br />

– the method referred to should be adjusted by including an<br />

element covering this risk, e.g. by using the approximation described in<br />

para 3.360-3.364 below. As always the choice of simplified methods<br />

should be advocated by the undertaking.<br />

3.322 It should also be mentioned that the calculations sketched above have<br />

disregarded the diversification effects between underwriting risk and<br />

counterparty default risk. 80 In the present context this should be viewed as<br />

a consequence of the trade-off between simplifications and accuracy that<br />

in general is present.<br />

80 In the <strong>Level</strong> 1 text the correlation coefficient between non-life underwriting risk and counterparty default risk<br />

has been set to 0.5 in the context of calculating the current SCR by the standard <strong>for</strong>mula.<br />

66/112<br />

© CEIOPS 2010

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