EIOPA has launched a public consultation on the capital requirement treatment of insurers’ direct exposure to qualified central counterparties (CCPs) within the standard formula.
The consultation paper notes that (re)insurers in the EEA have up until recently only used central clearing facilities indirectly as clients (i.e. through the intermediation of a clearing member) for their derivatives transactions. While Solvency II does prescribe a specific treatment for these indirect arrangements, direct exposures to CCPs have not been accounted for and as such would be treated as bilateral exposure, resulting in higher capital requirements.
Although there are no EEA (re)insurers at present with known traditional direct exposures to CCPs – as such a set-up may run counter to national law in certain Member States – clearing houses have evolved their access models. Under the so-called ‘sponsored model’, (re)insurers can now become direct members of CCPs with a sponsor handling default fund contributions and default management obligations on their behalf.
EIOPA assessed these developments together with the implications of different access models on insurers’ risk exposures, liquidity needs and the complexity of their risk assessment calculations. The consultation paper proposes three policy options:
- No change to the current regime (i.e. no recognition of the risk specificities of new access models and direct exposures);
- Extending the treatment of indirect exposures to direct exposures (i.e. more risk sensitivity but without capturing the particularities of default fund contributions);
- Further aligning the treatment of default fund contributions with the Capital Requirements Regulation – EIOPA’s preferred option as it also extends risks sensitivity to default fund payments.
Stakeholders are invited to provide their comments by 23 October 2024.