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Amendments to the implementing rules on solvency applicable to insurers

Banking and financial services

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Public consultation

ID: 1986

Lobbying Activity

18 responses

Consultation response

Vereniging VNO-NCW, 7 Dec 2018

There is an Europe-wide trend of insurers reducing their investments in equity (both stock exchange traded and private). There are many reasons for this, but the most important one is Solvency II, which entered into effect on 1-1-2016. To invest in equity, an insurer has to keep 39% of the amount…

Consultation response

Insurance Europe, 6 Dec 2018

Insurance Europe welcomes the opportunity to provide comments to the EC draft proposals for changes to the Solvency II Delegated Regulation. Please find enclosed the Insurance Europe position paper, which includes our general and specific comments on the EC draft proposals for changes to the…

Consultation response

Gesamtverband der Deutschen Versicherungswirtschaft e.V., 6 Dec 2018

Please see the attachment.

Consultation response

Invest Europe, 7 Dec 2018

Invest Europe, the association representing both private equity fund managers and investors in the asset class such as insurers, has long been in favour of reviewing the Solvency II risk-weights for unlisted equity. The current calibration does not appropriately capture the real risk of investing…

Consultation response

Associazione Bancaria Italiana, 7 Dec 2018

ABI welcomes the changes outlined in paragraph 38 of the draft, describing an assessment of credit quality steps (CQS) for unrated (by ECAIs) bonds and loans based on an approved internal model (Art. 176 C) which allows to lower the capital charges for these assets, introducing an assessment not…

Insurance Ireland urges lower capital costs for long-term insurers

Insurance Ireland, 7 Dec 2018

The organization requests lower financial safety requirements and more realistic calculation methods. They also advocate for simpler regulations for smaller firms to reduce administrative costs.
These changes would allow insurers to free up funds and lower customer premiums.

Consultation response

European Federation of Investors and Financial Services Users, 7 Dec 2018

BETTER FINANCE Feedback on rules for solvency of insurers (EC Delegated Regulation proposal of 8/11/2018, Article 171a - Long-term equity investments)

Consultation response

Unipol Assicurazioni S.p.A:, 7 Dec 2018

Unipol Group S.p.A. (hereinafter “Unipol”) welcomes the opportunity to provide comments on the EU Commission’s draft proposal to amend the Delegated Regulation (Delegated Regulation EU 2015/35) implementing rules for Solvency II, which represents a dossier of high importance for the insurance…

Consultation response

Associazione Nazionale fra le Imprese Assicuratrici, 6 Dec 2018

ANIA, the Association of Italian insurers, welcomes the opportunity to provide comments on the EC draft proposal for changes to Solvency II Delegated Regulation. In general, we share the comments on the various issues of the consultation drafted by Insurance Europe. Here we focus on a specific…

Consultation response

Schroders Investment Management (Europe) SA, 19 Nov 2018

We would like to provide feedback to the suggested changes outlined in paragraphs 36 – 38 of the draft, describing an internal assessment of credit quality steps (CQS) for unrated (by ECAIs) bonds and loans. We welcome the changes, which allow the insurers to use a robust and prescribed rating…

Consultation response

Swiss Re Ltd., 7 Dec 2018

Thank you for the opportunity to provide feedback on this draft Delegated regulation. Swiss Re welcomes the draft delegated regulation, however we are disappointed at the non-inclusion of the important topic of recognition of non-life non-proportional reinsurance. Swiss Re was part of industry…

Consultation response

International Credit Insurance & Surety Association, 6 Dec 2018

The members of ICISA, the International Credit Insurance & Surety Association, represent roughly 95% of the world’s private credit insurance business and a substantial part of the surety insurance business with over € 2 300bn of trade receivables coverage and billions of euros worth of…

Consultation response

Verband der Privaten Krankenversicherung e.V., 7 Dec 2018

Dear colleagues, We would like to thank you for the opportunity to comment on the planned changes to the Delegated Regulation in the short term. Please find our feedback enclosed. For further information please contact us at any time. Many thanks and kind regards German Association…

Consultation response

AMICE - Association of Mutual Insurers and Insurance Cooperatives in Europe, 7 Dec 2018

AMICE welcomes the opportunity to provide comments to the European Commission draft proposals for the changes to the Solvency II Delegated Regulation. We call for changes by the Commission in six areas (see detail in the document attached)

Consultation response

Actuarial Association of Europe, 7 Dec 2018

Thank you for the opportunity to provide feedback on this draft Delegated regulation. Please see attached document for the AAE submission. Actuarial Association of Europe

Consultation response

Reinsurance Advisory Board, 7 Dec 2018

Please find attached the Reinsurance Advisory Board's comments on the EC consultation on draft proposals for the Solvency II Delegated Regulation.

Consultation response

Bundesverband Alternative Investments e.V., 7 Dec 2018

Bundesverband Alternative Investments e.V. (BAI) is the cross-asset and cross-product advocacy association for the Alternative Investments industry in Germany. Our more than 200 member under-takings sponsor, manage, administrate or provide professional services for the entire range of open- and…

Consultation response

Fédération Nationale de la Mutualité Française, 6 Dec 2018

FNMF welcomes the opportunity to provide comments on the on the EC draft proposal for changes to Solvency II Delegated Regulation. We would also like to express our appreciation for the effort made by the Commission and the EIOPA to improve current Solvency II framework and to reduce the burden of…