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

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CEIOPS’ <strong>Advice</strong><br />

Simplifications regarding risk margin<br />

3.366 As a general principle, where an (re)insurance undertaking applies a<br />

simplified valuation method, this should be proportionate to the<br />

underlying risks and compatible with the Solvency II valuation<br />

principles. 85 This would apply irrespectively of whether the method is<br />

specified under <strong>Level</strong> 2 implementing measures or not.<br />

3.367 As a<strong>for</strong>ementioned, and as a general approach, especially in respect<br />

of best estimates simplifications, CEIOPS advises not to introduce an<br />

exhaustive list of methods and techniques as level 2 implementing<br />

measures <strong>for</strong> the estimation of the best estimate, and would prefer to<br />

keep such methods and techniques as level 3 guidance.<br />

3.368 However, CEIOPS recognizes that the risk margin is a specific area<br />

where additional considerations should be included in the level 2 text,<br />

due to the complexity and uncertainty around the calculation<br />

methodology, see para 3.369-3.372 below. Moreover, CEIOPS would<br />

support flexibility <strong>for</strong> undertakings to use other simplified methods or<br />

techniques, provided they can demonstrate that these are<br />

appropriate.<br />

3.369 If a full projection of all future SCRs is necessary in order to capture<br />

the undertaking’s risk profile – <strong>for</strong> all or some lines of business – the<br />

undertaking is expected to carry out these calculations.<br />

3.370 When an undertaking considers whether or not it would be appropriate<br />

to apply a simplified valuation technique <strong>for</strong> the risk margin, it should<br />

carry out separate assessments at least <strong>for</strong> each line of business. This<br />

means that a decision to use simplifications in one line of business<br />

should have no definitive impact on the decisions made <strong>for</strong> other lines<br />

of business. As an integral part of this assessment, the undertaking<br />

should consider what kind of simplified methods would be most<br />

appropriate <strong>for</strong> the given line of business. The chosen method should<br />

be proportionate to the nature, scale and complexity of the risks in the<br />

line of business in question.<br />

3.371 When the undertaking has decided to use a simplified method <strong>for</strong> a<br />

given line of business, it should consider whether the method could be<br />

used <strong>for</strong> the projections of the overall SCR (<strong>for</strong> the given line of<br />

business) or if the relevant (sub-)risks should be projected separately.<br />

In this context, the undertaking should also consider whether it should<br />

carry out the simplified projections of future SCRs individually <strong>for</strong> each<br />

future year or if it is possible to calculate all future SCRs in one step –<br />

but still <strong>for</strong> a given line of business.<br />

3.372 Based on the general principles and criteria referred to above, the<br />

following hierarchy could be seen as a possible decision basis regarding<br />

85 Cf. section 3.1.<br />

76/112<br />

© CEIOPS 2010

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