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

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(estimated) technical provisions gross of reinsurance and the<br />

(estimated) reinsurance recoverables. However, from a practical<br />

perspective it seems (more) likely that the wording of the <strong>Level</strong> 1 text<br />

should not prevent methods of calculations – including simplifications –<br />

whereby the technical provisions net of reinsurance is estimated in a first<br />

step, while an estimate of the reinsurance recoverables is fixed as a<br />

residual (i.e. as the difference between the estimated technical<br />

provisions gross and net of reinsurance, respectively). Accordingly, this<br />

approach has been chosen in the following discussion of the Gross-to-Net<br />

techniques that may be applied in the context of non-life insurance.<br />

Gross-to-net techniques<br />

3.386 Annex E of this paper contains a detailed analysis of the gross-to-net<br />

techniques (“proxies”) developed in the Report on Proxies elaborated by<br />

CEIOPS/Groupe Consultatif Coordination Group 90 as well as the gross-tonet<br />

techniques which were tested (based on the recommendations<br />

contained in this report) in the QIS4 exercise.<br />

3.387 This description of gross-to-net techniques has been included purely <strong>for</strong><br />

in<strong>for</strong>mational purposes; it is intended to provide an overview on the<br />

range and technical specificities of such methods developed so far.<br />

CEIOPS considers that further technical work may be relevant, <strong>for</strong><br />

example as additional level 3 guidance.<br />

3.4.2.1. Analysis<br />

3.388 This sub-section considers in general terms under which circumstances it<br />

would be appropriate to use gross-to-net techniques <strong>for</strong> a valuation of<br />

net technical provisions (and, following this, reinsurance recoverables)<br />

under the Solvency II framework, having regard to the proportionality<br />

assessment framework outlined in section 3.1.<br />

3.389 It first considers the compatibility of such techniques with the valuation<br />

principles set out in the <strong>Level</strong> 1 text. Further to this, the potential scope<br />

of an application of gross-to-net techniques is analysed. Finally, it is<br />

considered which level of detail/granularity would generally be needed in<br />

an application of gross-to-net techniques.<br />

3.390 In the advice, these considerations are used <strong>for</strong> setting general highlevel<br />

criteria to be followed by an (re)insurance undertaking applying<br />

gross-to-net techniques under the Solvency II framework.<br />

3.4.2.2. Compatibility of Gross-to-Net Calculations with the <strong>Level</strong> 1<br />

Text<br />

Reinsurance recoverables and net technical provisions<br />

3.391 As has been set out, the determination of reinsurance recoverables<br />

should follow the same principles as <strong>for</strong> the determination of gross<br />

technical provisions (i.e. it shall comply with Articles 76 to 80 of the<br />

<strong>Level</strong> 1 text), with an additional adjustment (imposed by Article 81) to<br />

take into account of expected losses due to counterparty defaults.<br />

90 CEIOPS/Groupe Consultatif Coordination Group: ”Report on Proxies”, July 2008.<br />

80/112<br />

© CEIOPS 2010

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