CEIOPS’ Advice for Level 2 Implementing Measures (https://register.eiopa.europa.eu/CEIOPS-Archive/Documents/Advices/CEIOPS-L2-Final-Advice-on-Standard-Formula-Market-risk.pdf?form=MG0AV3) states that: "the following investments shall be treated as equity and their risks considered accordingly in the equity risk sub-module: • an investment in a company engaged in real estate management, or • an investment in a company engaged in real estate project development or similar activities, or • an investment in a company which took out loans from institutions outside the scope of the insurance group in order to leverage its investments in properties. " Is it correct that levered property investment should have capital requirements based on the equity sub risk module as stated above? The underlying risk is more correctly modelled by stressing the property value with a property shock (rather than stressing the investment value with the equity shock).