Question ID: 1756
Regulation Reference: (EU) No 2015/35 - supplementing Dir 2009/138/EC - taking up & pursuit of the business of Insurance and Reinsurance (SII)
Article: 191, 212
Status: Final
Date of submission: 11 Nov 2018
Question
Where should be calculated the impact of mortage loan, if the amount of loan provided is 1 500 000 (is greater than 1 000 000) the duration is 5 years the callateral is 2 000 000.
The amount of this mortgage loan is greater than 1 000 000 and according to Article 191, p.4 can not be treated under Counterparty default risk.
The total amount owed to the insurance or reinsurance undertaking and, where relevant, to all related undertakings within the meaning of Article 212(1)(b) and (2) of Directive 2009/138/EC, including any exposure in default, by the counterparty or other connected third party, shall not, to the knowledge of the insurance or reinsurance undertaking, exceed EUR 1 million. The insurance or reinsurance undertaking shall take reasonable steps to acquire this knowledge.
EIOPA answer
In case the mortgage loan does not meet the requirements set out in Article 191 of Commission Delegated Regulation (EU) 2015/35 it should be included in the calculation of the capital requirements for interest rate risk, spread risk and market risk concentration as well as in case relevant for currency risk.