Question ID: 1466
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Template: S.26.01
Status: Final
Date of submission: 20 Feb 2018
Question
How should assets/liabilities before/after shock be presented in S.26.01, in particular in rows concerning interest rate risk.
There are 3 possible ways to present data.
1. All assets/ liabilities (before and after shock) which are sensitive to interest rate risk should be presented (irrespectively if it is up/down shock)
2. Only assets/liabilities sensitive to given shock should be presented before and after shock meaning that there is a capital charge for those assets/liabilities
3. Before shock: all assets/ liabilities which are sensitive to interest rate risk should be presented (irrespectively if it is up/down shock); after shock: for currencies causing capital charge - value after shock is presented, for currencies causing no capital charge - value before shock is presented.
According to Q&A no 443, 583, 807,759:
• only the amounts “sensitive to the risk” should be filled in in both assets and liabilities.
• “Sensitive to risk” should be understood as a risk-increasing effect not necessarily in SCR terms but in terms of the real risk exposure.
• if capital charge is zero, it doesn’t mean that asset/liabilities is not sensitive to risk (e.g. European government bonds)
• the amounts reported under columns before and after shock should be consistent.
• contracts, whose Technical Provisions decreases after shock are not sensitive to that risk and thus this Technical
Provisions should not be presented (this Q&A concerned mortality risk).
EIOPA answer
All assets/liabilities before and after shock that are sensitive to interest rate risk should be presented in the S.26.01 no matter if it is up or down shock (option 1).
Regarding Q&A no 443, 583, 807,759 please see our comments as follows:
· We confirm that only the amounts "sensitive to the risk" should be filled in in both assets and liabilities.
· Option 2 does not comply with the statement that "Sensitive to risk" should be understood as a risk-increasing effect not necessarily in SCR terms but in terms of the real risk exposure.
· Option 2 does not comply with the statement that if capital charge is zero, it doesn't mean that asset/liabilities is not sensitive to risk (e.g. European government bonds).
· Option 3 does not comply with the statement that the amounts reported under columns before and after shock should be consistent.
· Regarding the statement that contracts, whose Technical Provisions decrease after shock, are not sensitive to that risk and thus these Technical Provisions should not be presented EIOPA highlights that this statement concerned a Q&A on mortality risk. Regarding interest rate shock all assets/liabilities before and after shock that are sensitive to interest rate risk should be presented.