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Group
Support Regime and Group Supervision
from the Solvency ii
Association, the largest Association of Solvency ii Professionals
in the world
Consultation
Paper No. 60
Draft CEIOPS’ Advice for Level 2 Implementing
Measures on Solvency II: Assessment of Group Solvency
Advice
3.1. Definition of group and
consolidation
3.1.
Some of the advice in this paper may need to be adjusted or refined to take account of
the reviews of other financial services directives.
For
example, this may affect CEIOPS advice on the entities that fall
within the scope of group supervision.
3.1.1. Definition of group and scope of
consolidation
The definition of a “group” for regulatory
purposes
3.2.
According to recital 65 of the level 1 text, group supervision
should take into account insurance holding
companies and mixed-activity insurance holding companies to the
extent necessary.
However,
it does not imply that Member States are required to apply
supervision to those undertakings considered
individually.
3.3.
According to Recital 66 of the level 1 text, whilst the supervision
of individual insurance and reinsurance undertakings remains the
essential principle of insurance supervision, it
is necessary to determine which undertakings fall under the scope of
supervision at group level.
3.4.
Article 233 states that
“where insurance and reinsurance undertakings are
subsidiaries of an insurance holding company, the group supervisor
shall ensure that the calculation of the solvency of the group is
carried out at the level of the insurance holding company applying
Articles 218(2) to 231. ”
3.5.
Article 218 states that:
“the calculation of
the solvency at the level of the group of the insurance and
reinsurance undertakings referred to in point (a) of Article 211(2)
shall be carried out in accordance with the technical principles and
one of the methods set out in Articles 219 to
231.”
3.6.
Therefore, CEIOPS considers it is important to clarify the scope of
group supervision refered to in Article 211.
The
definitions used in title III of the Level 1 text are found in
Articles 13 and 210.
3.7.
Article 210(1)(c)(i) states that:
“group”
means a group of undertakings, that consists of a participating
undertaking, its subsidiaries and the entities in which the
participating undertaking or its subsidiaries hold a participation,
as well as undertakings linked to each other by a relationship as
set out in Article 12(1) of the Directive 83/349/EEC (see Annex
3).
3.8.
Article 13(15) defines the notion of control according to the
consolidated accounts Directive 83/349/EEC.
It also
defines which entities should be taken into account when performing
group supervision as:
• participating undertakings in the (re)insurance
undertaking;
• related undertakings of the (re)insurance
undertaking; and
• related undertakings of a participating
undertaking in the (re)insurance undertaking.
3.9.
The level 1 text, like the Insurance Groups Directive 98/78/EC
(IGD), specifically includes the concept of dominant
influence.
3.10.
“Participation” means the ownership, direct or
by way of control, of 20 % or more of the voting rights or capital
of an undertaking (Article 13 (16)).
The
supervisory authorities shall also consider as
participation the holding, directly or indirectly, of voting rights
or capital in an undertaking over which a significant influence is
effectively exercised.
3.11.
The following graph illustrates the entities
that have to be considered when performing the group
supervision:
3.12. For the purposes of
group supervision, the supervisory
authorities shall also consider as a parent undertaking any
undertaking which, in the opinion of the
supervisory authorities, effectively exercises a dominant influence
over another undertaking.
They shall also consider as
subsidiary undertaking any undertaking over which a parent
undertaking effectively exercises a dominant influence (Article
210(2)).
3.13. Moreover, Article 13
states that :
• (14) “close links” means
o a
situation in which two or more natural or legal persons are linked
by control or participation,
o or a
situation in which two or more natural or legal persons are
permanently linked to one and the same person by a
control
relationship;
• (15) “control” means:
o the
relationship between a parent undertaking and a subsidiary
undertaking, as set out in Article 1 of Directive
83/349/EEC,
o or a
similar relationship between any natural or legal person and an
undertaking;
3.14. For the purpose of
group solvency calculation, the
regulatory group could be composed by the (re)insurance undertaking
or insurance holding company at the top level of the group and by
its related insurance/reinsurance/financial undertakings.
Moreover, Article 212(2)
allows insurance supervisors to exclude entities from
the calculation.
3.15. Article 212(2)
states that the group supervisor may decide on a
case-by-case basis not to include a (re)insurance undertaking
in the group supervision referred to in Article 211 in the following
cases:
a) if
the undertaking is situated in a third country where there are legal
impediments to the transfer of the necessary information, without
prejudice to the provisions of Article
227;
b) if the
undertaking which should be included is of negligible interest with
respect to the objectives of group
supervision;
c) if
the inclusion of the undertaking would be inappropriate or
misleading with respect to the objectives of the group
supervision.
However, where several
undertakings of the same group, taken individually, may be excluded
pursuant to point (b) of the first
subparagraph (of article 212)
they must nevertheless be included where, collectively, they are of
non-negligible interest. (…)
3.16. CEIOPS considers
that the principle established through the different definitions and
articles is that all parts of the group necessary to ensure a proper
understanding of the group and the potential source of risks within
the group have to be included within the scope of group
supervision.
3.17. CEIOPS notes that
similar issues concerning the scope of the group and the treatment
of participations are being dealt with as part of the Financial Conglomerates Directive (FCD) review
being undertaken by the Joint Committee on Financial Conglomerates
(JCFC).
The FCD review focuses on
definitions, scope and internal control requirements, and how these
areas and implementation may impact on the fulfilment of the
objectives of the FCD.2
CEIOPS’ advice
3.18.
CEIOPS considers that all parts of the group necessary to ensure a
proper understanding of the group and the potential sources of risks
within the group have to be included within the scope of group
supervision.
Mutual or
mutual-type associations
3.19. According to Recital
66(a), mutuals and mutual-type associations, subject to Community
and national law, are able to come together by
constituting concentrations or groups.
Those groups are mostly not constituted with capital ties but through
formalised strong and sustainable relationships, based on
contractual or other material recognition that guarantees a
financial solidarity between the mutuals or mutual-type
associations.
3.20. Article
210(1)(c)(ii) states that:
“group” means a group of
undertakings
(ii)
that is based on the establishment, contractually or otherwise, of
strong and sustainable financial relationships among
those
undertakings, and that may include mutual or mutual-type
associations, provided that:
- one of
those undertakings effectively exercises, through centralised
coordination, a dominant influence over the decisions, including
financial decisions, of the other undertakings that are part of the
group; and
- the
establishment and dissolution of such relationships for the purposes
of this Title are subject to prior approval by the
group
supervisor.
The undertaking exercising
the centralised coordination shall be considered as the parent
undertaking, and the other undertakings shall be considered as
subsidiaries;
3.21. Where a significant or dominant influence is exercised
through a centralised coordination, the mutuals and mutual-type
associations shall be supervised according to
the same rules as those provided for groups constituted
through capital ties in order to achieve an adequate level of
protection for policyholders and a level playing field between
groups.
3.22. CEIOPS views
centralised coordination within the meaning of Article 12(1) of the
Directive 83/349/EEC.
3.23. Undertakings are usually part of
the group by means of holding voting rights or capital in the
subsidiary.
However, for the purposes of
the Level 1 text, they are also part of the group under the
circumstances described in article 12 of the Consolidated Accounts
Directive.
3.1.2 Definition
of dominant influence and significant
influence
3.24. According to Article
219(2) :
“The group supervisor
shall determine, after consultation with the other supervisory
authorities concerned and the group itself, the proportional share which shall be taken into account
in the following cases:
(a) where
there are no capital ties between some of the undertakings in a
group;
(b) where a
supervisory authority has determined that the holding, directly or
indirectly, of voting rights or capital in an
undertaking
qualifies as a participation because, in its opinion,
a significant influence is effectively exercised over that
undertaking;
(c) where a
supervisory authority has determined that an undertaking is a parent
undertaking of another because, in the opinion of the supervisory
authority, it effectively exercises a dominant influence over that
other undertaking.”
3.25. For the purpose of
group supervision, the main characteristic of a
parent subsidiary relationship is control.
Undertakings are usually
controlled by means of a holding in voting rights or capital in the
subsidiary.
3.26. As mentioned above,
Article 13(15)(a) of the level 1 text states that control means the relationship between a parent
undertaking and a subsidiary undertaking, as set out in Article 1 of
Directive 83/349/EEC, or a similar relationship between any natural
or legal person and an undertaking.
3.27. This Article
includes a range of situations in which an undertaking has a
majority of the shareholders' voting rights in another undertaking
(a subsidiary undertaking), including the right to exercise a
dominant influence over the management on a unified
basis.
3.28. According to Article
210(2) an undertaking should also be considered as a
subsidiary if, in the opinion of the supervisory authorities, a
dominant influence is effectively exercised by its parent
undertakings.
Under the same article, an undertaking should also be considered as a related
undertaking if a significant influence is effectively exercised by
its parent undertakings.
3.29. According to the
Article 33.1 of the Consolidated Accounts Directive, “an undertaking
shall be presumed to exercise a significant influence over another
undertaking where it has 20 % or more of the
shareholders’ or members’ voting rights in that
undertaking.”
3.30. Therefore according
to the Consolidated Accounts Directive
(see Annex 3), significant and dominant influence is defined as
follows:
• Significant influence is
where an undertaking has 20% or more of the shareholders’ or
members’ voting rights in another
undertaking.
That means the group has
the power to participate in financial and operational policy
decisions, but not control them.
• Dominant influence is
where an undertaking has more than 50% of the shareholders’ or
members’ voting rights in
another
undertaking.
3.31. Significant and dominant influences in the Level 1
text are wider concepts than in the Consolidated Accounts Directive.
It refers not only to the
relationships among undertakings, but also to the relationships
between natural persons and undertakings.
This is the
approach under Article 2(13)(b) of the Financial Conglomerates
Directive (FCD).
The Level 1 text lays down
quantitative thresholds for dominant and significant influence, but
also states that such an influence may be identified by
supervisors.
3.32. Therefore there is a need for supervisors to check if the
concept of control used for the establishment of the statutory
consolidated accounts is consistent with the level 1 text.
A dominant influence may exist for regulatory
purposes, but not for the establishment of the statutory
consolidated accounts.
3.33. The degree of influence determines whether the
entities are included within the scope of group supervision.
It must be noted that the
assessment of dominant influence could have a direct impact on the
membership of the college of supervisors as in that case, the entity
will be treated as a subsidiary and the supervisory authority
responsible for the subsidiary will become a member of the College
in accordance with article 252(3) if the subsidiary is in the
EEA.
3.34. A holding of 20% or more of the voting rights
(directly or indirectly or through natural persons) will indicate
significant influence.
If the holding is
less than
20%, the investor will be presumed not to have significant influence
unless such influence can be clearly demonstrated.
This significant influence has
also to be assessed when there several intermediary levels
exist.
3.35. If two or more entities
are subject to the significant influence of a parent, owner company,
investor (including a natural person), or common officers or
directors, those entities shall be considered as related parties
with respect to each other.
3.36. Significant and
dominant influence is usually evidenced in one or more of the
following ways:
• representation on the
board of directors or equivalent governing body of the
investee;
• participation in the
policy-making process;
• material transactions
between the investor and the investee;
• interchange of
managerial personnel;
• provision of essential
technical information;
• managed on a unified
basis;
• potential voting rights
(e.g. exercise of warrants).
3.37. The loss of dominant
influence, significant influence or joint control represents a
significant economic event that changes the nature of an investment.
In the case of a loss of
dominant influence, the entity is no longer considered as a
subsidiary undertaking.
CEIOPS’ advice
3.38.
Significant
and dominant influences in the Level 1 text are
wider concepts than in the Consolidated
Accounts Directive.
They refer
not only to
the relationships between undertakings, but also to the
relationships between natural persons and undertakings.
Although the Level 1 text lays
down quantitative thresholds, a dominant or a significant influence
may also be identified by supervisors.
3.39. CEIOPS considers
that significant and dominant influence is usually evidenced in one
or more of the following ways:
• representation on the
board of directors or equivalent governing body of the
investee;
• participation in the
policy-making process;
• material transactions
between the investor and the investee;
• interchange of
managerial personnel; • provision of essential technical
information;
• managed on a unified
basis;
• potential voting
rights.
3.1.3 Treatment of
participations in the calculation of the group
SCR
3.40. The treatment of
participations at group level should be based on the following
criteria:
- The classification and
method of the participation should be based on economic principles
and not merely on legal grounds.
Control and influence should
always be assessed firstly at group level to establish the
significance of the participations.
This ensures that situations
where several entities of a group have small participations in the
same undertaking are not
overlooked.
- In line with the principle
above, the consolidation approach used for accounting purposes
should be used for solvency purposes to the extent they are based on
economic principles suitable for a solvency
assessment.
- The treatment of
participated undertakings should be accompanied by an appropriate
treatment under Pillar II and Pillar
III.
- The choice of the method
should be made under the proportionality principle as per Article
28.
3.41. The consolidated
accounts is the consolidation based on the scope of the regulatory
group for regulatory purposes (i.e with the necessary adjustments
referring to art 226 and art 227 and any other measures taken by the
group supervisor).
3.42. Regulated financial
entities with capital requirements should be included in the group
calculation using the deduction and aggregation method when it is
not possible to include them through the consolidated accounts.
This is to ensure there is
no
circumvention of the sectoral rules.
3.43. One particular area
of relevance in the review of the FCD for insurance group
supervision is the identification of participations and the concept
of ‘durable link’.
While ‘durable link’ is not a
concept in the Level 1 text, the issue is related to the
identification of significant influence in determining a
parent-participation relationship.
The lack of a clear definition
of ‘durable link’ and its potential inconsistency with IAS 28
guidelines on significant influence has resulted in MS interpreting
the concept differently, creating some variance in the application
of conglomerate supervision.
CEIOPS notes that the JCFC is
considering ways to promote a more consistent cross-sectoral
approach to the treatment of participations, including the
development of guidance material.
3.44. The JCFC is also
assessing the impact of where the inclusion of participations is a
trigger for the identification of the group as a financial
conglomerate.
CEIOPS notes that this work is
relevant to the identification of a group under Solvency II. Article
212(2) of the Level 1 text is consistent with Article 6(5) of the
FCD in providing supervisory discretion in determining the scope of
the group.
The JCFC is also analysing the
impact of the different treatment of participations.
The experiences of the
different treatment of participations at group level for financial
conglomerates is relevant to CEIOPS as it develops its approach for
participations at both solo and group level.
Consolidation
methods for (re)insurance undertakings
3.45.
There are
differences between the statutory accounting balance sheet and the
group regulatory balance sheet as the reporting serve two different
purposes.
For example, prudential
filters have to be developed for the regulatory balance sheet.
This can make them hard to
compare.
3.46.
CEIOPS considers
that the statutory accounting balance sheet should be used as the
basis for consolidation.
The starting point for
solvency purposes, where International Financial Reporting Standards
apply, may have to be adjusted to account for changes in
international accounting standards.
Since 1 January 2005, European
listed companies have had to publish, as a minimum, consolidated
financial statements based on the new
International Financial
Reporting Standards (IFRS) rules.
The IFRS accounting
developments constitutes one of the input to assess the magnitude,
the quality and volatility of institutions’ eligible own
funds.
3.47. Entities which are
part of the regulatory group but excluded from the accounting group
must be consolidated in any case for regulatory purposes (method 1)
or they should be taken into account using the deduction aggregation
method.
However, CEIOPS recognises
that often the accounting consolidation group is larger than the
regulatory one.
3.48. Where a
participation in an EEA (re)insurer is regarded as a dominant
influence this will imply a full integration of the participation in
the accounts or a proportional integration (if there is jointly
shared control of the participation).
In the case of a fully
integrated participation, minority interests would in turn
contribute to cover part of the group SCR (see
section
3.4.3).
3.49.
Where a
participation in an (re)insurer is regarded as significant
influence, the contribution to the group SCR should be calculated as
the group’s share in the participation multiplied by the solo SCR of
this participation.
This is consistent with
the equity method consolidation where such participations are
accounted for at equity value in the group's consolidated accounts.
Participations where
significant influence is exercised shall contribute to the group SCR
in the sum of respective share's in each
individual SCR,
calculated as referred above in this paragraph.
If the solo SCR of the current
year is not available, then as a proxy the previous SCR should be
used, adjusted for the annual movement in
premiums.
3.50. When there is no
significant or dominant influence, the contribution to the group SCR
in respect should be calculated by applying the relevant risk
charges in the same manner as in solo
calculations.
Related credit institutions, investment
firms and financial institutions
3.51. Article 226 states
:
“When
calculating the group solvency of an insurance or reinsurance
undertaking which is a participating undertaking in a credit
institution, investment firm or financial institution, Member States
shall allow their participating insurance and reinsurance
undertakings to apply mutatis mutandis methods 1 or 2 set out in
Annex I to Directive 2002/87/EC.
However,
method 1 set out in that Annex shall be applied only if the group
supervisor is satisfied as to the level of integrated management and
internal control regarding the entities which would be included in
the scope of consolidation.
The method
chosen shall be applied in a consistent manner over
time.
Member
States shall however allow their supervisory authorities, where they
assume the role of group supervisor with regard to a particular
group, to decide, at the request of the participating undertaking or
on their own initiative, to deduct any participation as referred to
in the first paragraph from the own funds eligible for the group
solvency of the participating undertaking.”
3.52. Regulated asset
management companies are covered under Article
226.
3.53. The treatment of the
other financial regulated entities should be consistent with the
Financial Conglomerate Directive (FCD).
CEIOPS
interpretation of the text is that the group is in effect treated
as if it were a
financial conglomerate for group solvency purposes.
3.54. The calculation
methods set out in the annex 1 of the FCD do not consider a possible
diversification between sectors and prescribe the use of sectoral
rules.
The rationale behind is that
there are different solvency requirements for different financial
entities.
3.55. Therefore,
the group
solvency of the insurance group would reflect the combination of the
own funds and solvency requirements of the insurance and
non-insurance undertakings based on the relevent sectoral rules
(subject to the calculation method applied).
3.56. In the case of
financial non-regulated undertakings, a notional capital requirement
should be calculated.
Institution for
occupational retirement provision (IORP)
3.57. According to recital
95.b of the level 1 text:
'Article 17(2) of
Directive 2003/41/EC of the European Parliament and of the Council
of 3 June 2003 on the activities and supervision of institutions for
occupational retirement provision refers to the existing legislative
provisions on solvency margins. Those references should be retained
in order to maintain the status quo’.
3.58. Similar to credit
institutions, investment firms and financial institutions, IORP
undertakings are subject to the relevant sectoral rules.
Therefore,
potential
diversification benefits between IORP undertakings and
other entities within groups should
not be considered.
Insurance
holding companies and mixed activity insurance holding
companies
3.59. According to recital
65, “Such group supervision should take into
account insurance holding companies and mixed activity insurance
holding companies to the extent necessary.
However, this
Directive should not in any way imply that Member States are
required to apply supervision to those undertakings considered
individually.”
3.60. CEIOPS considers
that controlled insurance holding companies should be consolidated,
that is a full integration of the participations in the intermediate
insurance holding company and in the insurance undertakings
participated by the insurance holding
company.
3.61. An insurance holding
company has to be included in the scope of the regulatory group to
prevent down streaming of lower quality capital items as higher
quality capital to regulated subsidiaries.
3.62. As insurance holding
companies can be established in a different jurisdiction than the
parent undertaking, cooperation between supervisors is of utmost
importance.
Any material external market
and default risk in holding companies should be
addressed.
Non-regulated
non-financial entities
3.63.
As a general
principle, participations in entities outside the banking and
(re)insurance sectors (both dominant and significant influence)
should be consolidated.
However, they should be
included in the group SCR as at solo level.
3.64. Only the ancillary
entities that are subject to a dominant influence should be
consolidated through a full integration of the participation in the
accounts.
Ancillary entities, are
entities, of which the principal activity consists
in:
- owning or managing
property;
- managing data-processing
services;
- or any other similar
activity which is ancillary to the principal activity of an
insurance undertaking
3.65. Non-regulated,
non-financial and non ancillary entities in the group are not
subject to solo supervision as single
entities.
CEIOPS’ advice
3.66. The treatment of
participations at group level should be based on the following
criteria:
- the classification and
method of the participation should be based on economic principles,
not just on legal grounds.
Control and influence should
always be assessed at a group level to determine the significance of
participations.
This ensures that situations
where several entities of a group have small participations in the
same undertaking are not
overlooked.
- In line with the principle
above, the consolidation approach used for accounting purposes
should be used for solvency purposes to the extent they are based on
economic principles suitable for a solvency
assessment.
- The treatment of
participated undertakings should be accompanied by an appropriate
treatment in Pillar II and Pillar
III.
3.67. Regulated financial
entities with capital requirements should be included in the group
calculation using the deduction aggregation method when it is not
possible to include them through the consolidated method.
This is to ensure there is no
circumvention of the sectoral rules.
3.68. The choice of the
method should be made under the proportionality principle as per
Article 28.
3.69. Nevertheless, the
following principles may apply for (re)insurance participations in
accordance with IAS/IFRS and national general accounting
principles.
3.70. When the group’s
participation in an EEA (re)insurer is regarded as a dominant
influence this will imply a full integration of the participation
in the accounts or a proportional integration (if there is jointly
shared control of the participation).
In the case of a fully
integrated participation, minority interests would in turn
contribute to cover part of the group SCR.
3.71.
Where significant
influence is exercised the contribution to the group SCR in respect
of the participation should be calculated as the group’s share in
the participation multiplied by the solo SCR of this participation.
This is consistent with the
equity method consolidation where such participations are accounted
for at equity value in the group's consolidated accounts.
The contribution of these
participations to the group SCR would be the sum of the
above-mentioned calculations.
3.72. When there is no
significant or dominant influence, the contribution to the group SCR
in respect should be calculated by applying the relevant risk
charges in the same manner as in solo
calculations.
3.73. CEIOPS
interpretation of Article 226 is that, where the group supervisor
gives permission to apply the FCD calculations, the group is in
effect treated as if it were a financial conglomerate for group
solvency purposes.
3.74.
Related credit
institutions, investment firms and financial institutions shall, in
accordance with the Financial Conglomerates Directive, be included
in the group calculation using sectoral requirements and not allow
for diversification.
3.75. In case of financial
non-regulated undertakings a notional capital requirement shall be
calculated.
3.76. Institutions for
occupational retirement provision shall be included in the group
calculation using sectoral requirements and not allow for
diversification.
3.77.
As insurance holding
companies or mixed activity insurance holding companies can be
established in a different jurisdiction than the parent undertaking,
cooperation between supervisors is of utmost
importance.
Any material external
market and default risk in holding companies shall be
addressed.
3.78. Controlled insurance
holding companies or mixed activity insurance holding companies
shall be consolidated, that is a full integration of the
participations in the intermediate insurance holding company and in
the insurance undertakings participated by the intermediate
insurance holding company or mixed activity insurance holding
company is required.
3.79. As a general
principle, participations in entities outside the banking and
(re)insurance sectors (both dominant and significant influence)
should be consolidated.
However, they shall be
included in the group SCR as at solo level.
3.80.
Controlled ancillary
entities should be consolidated, that is a full integration of the
participation in the accounts is required.
As a general principle, the
capital charge shall be the same as at solo
level.
3.81. As a general
principle, the capital charge attributed to entities outside the
financial sector shall be the same as at solo
level.
3.82. The proposed
accounting treatments for the regulatory balance sheet (see table in
Annex 5) are in line with the international accounting
standards.
CEIOPS welcome any
comments on the practicability of those treatments for the groups
using national GAAPs.
Non-availability
of the necessary information
3.83. Article 227
states:
Where the information
necessary for calculating the group solvency of an insurance or
reinsurance undertaking, concerning a related undertaking with its
head office in a Member State or a third-country, is not available
to the supervisory authorities concerned, the book value of that
undertaking in the participating insurance or reinsurance
undertaking shall be deducted from the own funds eligible for the
group solvency.
In that case, the
unrealised gains connected with such participation shall not be
recognised as own funds eligible for the group
solvency.
3.84. If the undertaking
is situated in a third country there may be legal impediments to the
transfer of information. Information concerns may also arise for EEA
and third country related undertakings for which there is only a
significant and not a dominant influence.
3.85. Information
concerning a related undertaking available for the statutory
accounting consolidation (e.g. technical provisions in local GAAP)
may not necessarily be available for the regulatory consolidated
accounts.
On that basis,
the group
should demonstrate that the information necessary for calculating
the group solvency is adequate. If supervisors are not satisfied of
the adequacy of the information, article 227 shall apply and then
the related undertaking should be deducted.
CEIOPS’
advice
3.86.
Information
concerning a related undertaking available for the statutory
accounting consolidation (e.g. technical provisions in local GAAP)
may not necessarily be available for the regulatory consolidated
accounts.
On that basis, the group shall
demonstrate that the information necessary for calculating the group
solvency is adequate. If supervisors are not satisfied of the
adequacy of the information, article 227 shall apply and then the
related undertaking should be deducted.
Consultation Paper No. 60
Draft CEIOPS’ Advice for Level 2 Implementing Measures on Solvency
II: Assessment of Group Solvency
1.
Assessment of Group Solvency - Introduction
2.
Level 1 Text
3.
Advice from CEIOPS
4.
Third Countries
5.
Calculation Method
6.
Fungibility and Transferability
7.
Transferability of Own Funds
8.
Calculations
9.
Annex 1 to Annex 5
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Index
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