Topic Date Question Answer
ASL Sep-10 Will Lloyd’s be providing the look through investment information required on Lloyd’s centrally held assets This information was provided to the market on 1 October, along with details of overseas trust funds and third party FAL.
such as ASL?
ASL Oct-10 The ASL breakdown spreadsheet that Lloyd’s produced last week does not have a breakdown for Bahamas Bahamas funding was first collected in 2010, hence it is not applicable for QIS5 which applies to 31/12/2009 year end.
securities – how should we treat these securities?
Asset classification Sep-10 Item 3, information on spreads aggregates - is this section for non-EEA governments, issued in their own The helper tab spread risk calculation spreadsheet is used for all non-EEA bonds. This should be completed as follows:
currency and then converted to the reporting currency? For example, we have a lot of US Gov’t Bonds, (i) Covered bonds, select "covered"
issued in USD but no US Bonds in GBP (the reporting currency) (ii) Sovereign bonds issued in domestic currency (i.e currency of the issuing country), select "Non-EEA sovereign"
(iii) Sovereign bonds issued in currency of an EEA state (e.g EURO, GBP), select "Non-EEA sovereign"
(iv) All other Non-EEA government bonds and corporate bonds, select "No"
Asset classification Sep-10 We are entering on the helper tab for spread risk our exposures to US Government stock issue in it's This should be used for all Non-EEA government bonds, covered bonds and corporate bonds. In the case of US Government stock issued
domestic currency of US$, we are entering this as "Non EEA Sovereign, which produces no capital in US$, select "Non-EEA sovereign"
requirement. However reading the Lloyd's Q+A for September 2010 under Topics "asset classification" an
answer states that; "If the syndicate is reporting in GBP, then this section should be populated with bonds
that are issued in GBP by non EU country governments." Therefore under which section should we enter
US Government stock issue in US$, "No", "Covered Bond" or "Non EEA Sovereign".
Assets Sep-10 Are the balance in the CICR, CILF etc that are reported on line 1 of QMA form 002 “Listed” or “Unlisted”? CICR is unlisted while CILF is listed
Asset valuation Oct-10 Regarding risk asset valuation – is this should be the market value of the assets plus the accrued interest? When assessing the spread risk, "clean" market value should be used because it would be the capital amount that would be affected by a
You can purchase and sell the accrued interest, there is an inherent risk that its value could fall to zero if change in spread. However, the "dirty" market value should be used in the concentration risk module.
the assets default, also there is the risk that the issuer will not pay the coupon on it. The accrued interest is
included on the balance sheet, so shouldn't this should be included?
Bonds Sep-10 Please will you clarify the following in relation to the detailed QIS5 guidance for provided by Lloyd's: These are forms of structured products, hence they should be included in columns J to AB.
Allocation of ABS, CMO and CMBS bonds. The ABS, CMO and CMBS bonds disclosed in line 2 of form
QMA2 should be used in the "spread" helper tab in the bond calculation (columns B to H) and not structured
credit calculation (columns J to AB) .
Bonds Sep-10 Having reviewed the Technical specification (TP 5.88 & 5.124), it appears that Agency bonds and Agency bonds issued by a US Government-sponsored agency are backed by the US government, but not guaranteed by the government
Government Guaranteed Corporate Bonds actually carry no capital requirement if they are demonstrably since the agencies are private entities. In the case of banks partly owned by the government, their bonds are not guaranteed by the
guaranteed by the national government of an EEA state, issued in its own currency, so shouldn’t be treated government. Only those bonds that are demonstrably guaranteed by a national government should be treated as government bonds. Hence
as Corporate bonds as you mention below. Would you be able to confirm this for me please? Also, why can agency bonds and those bonds issued by banks partly owned by the government should be treated as corporate bonds in the determination
the same not apply to those holdings guaranteed by governments such as the USA, given that their credit of capital charge.
rating is higher than some of the EEA state members? It appears counter-intuitive that a bond that yields far
less than a Corporate and carries far less risk than a Corporate, should carry the same capital requirement
as a Corporate bond. Essentially, if we are going to be penalised in this way, we may as well transfer all of
our holdings out of the “safe” investments and into “risky” Corporate investments. Is this something we can
address to CEIOPS?
CICR funds Sep-10 We have funds that are held in CICR, these are reported in QMA2 Line 1. According to the instructions CICR should not be reported under participations. CICR and CILF should be treated in the valuation tab as cash and cash equivalents.
under QIS5 they are to be reported under assets as participations. Are you expecting to see this in the
participations tab, if so how do we classify it?
Counterparty risk Sep-10 In the assets tab for Counterparty default risk are you expecting the values to be based on the helper tab from If you use the helper tab to complete this section, then yes.
CEIOPS ?
Counterparty risk Sep-10 This is section 5 on the Assets tab and there is a helper tab to help you complete. More guidance for the Section SCR.6 of the QIS5 technical specification contains further information about what should be included within this module, but
helper tab would be good e.g. What is the definition of recoverable, I assume RI on premiums and claims broadly speaking, the risk associated with defaults by all counterparties should be included within this risk module. Any amounts
provisions (but what about paid RI accruals)? (including reinsurance recoveries) that are yet to be received from a counterparty, even if agreed, must be captured. This risk module also
captures the effect on the underwriting and market risk SCRs of the loss of risk mitigation from each reinsurance contract. Believe that the
default risk charge calculated by the helper sheet does depend on how many reinsurers are listed. Grouping together does seem to
increase capital charges (presumably diversification effects). We are not aware of any simplifications available under QIS5, other than that
mentioned in Section SCR.6.54 which relates to splitting up the effect on the SCR by reinsurer.
Counterparty risk Sep-10 This is section 5 on the Assets tab and there is a helper tab to help you complete. More guidance for the For completeness, the recoverables from reinsurance arrangements for the purpose of the SCR calculation should include all amounts
helper tab would be good e.g. What is the definition of recoverable, I assume RI on premiums and claims due from counterparties and so, unlike the technical provisions, should include paid RI accruals. QIS5 does allow for simplifications on the
provisions (but what about paid RI accruals?). Also in QIS4 we were able to use a simplification putting counterparty default module and so banding by credit rating would be acceptable (assuming an equal probability of default within the rating.
reinsurers in the 6 banding groups rather than listing each one separately, are we allowed to do this again? Note SCR.6.57 - default probabilities used must be the highest of those within the group).
Currency Sep-10 On the Assets tab in section 2 (information on currency risk) what components of the balance sheet should This should be the whole trial balance.
be included here e.g. is all assets or just investments or is it the whole trial balance?
Currency Sep-10 Agents should enter, "in the currency of the spreadsheet (required to be Sterling), details of their assets All foreign currency assets/liabilities should be entered, in Sterling. The chosen treatment should allow for capturing all exposure to
and liabilities exposed to currency risk, split by currency shown.” I assume that effectively this is all assets currency risk, (with some allowance for materiality).
and liabilities to tie up to the assets and liabilities total on the valuation tab (but on a current basis or S2
basis) . And I also assume that materiality would apply to splitting assets and liabilities between currencies,
the normal 4 currencies but also what about non pure convertible £ as we have to disclose for technical
provisions? No obvious line for this so I assume not. Can you confirm treatment please?
Currency risk Oct-10 I was completing the assets tab. For the currency risk my methodology is to determine total assets and Assuming that by "RESERVES" you mean members' balances and not technical reserves, then your approach is correct.
convert them at year end rates for each currency. Then determine total liabilities excluding RESERVES and
converting them at year end rates. Is that the correct way to approach it?
Government securities Sep-10 How are regional / municipal government securities to be treated? As per CEIOPS' FAQ no. 56, page 44 ( https://www.ceiops.eu/fileadmin/tx_dam/files/consultations/QIS/QIS5/CEIOPS-Q-and-A-document-
20100923.pdf), " The capital requirement for local authority bonds is "0" in credit spread risk and market risk concentrations only when
local authority bonds are demonstrably guaranteed by national government of an EEA state and are issued in the currency of the
government. Otherwise, standard risk factors should be applied." This means that if the bonds do not meet the above requirement, then they
should be treated as corporate bonds.
Internal Models Oct-10 At present we do not have a working internal model, as we are not yet at this stage in the dry-run process. Please see pages 4 and 36 of QIS5 guidance, stating that agents should allocate Internal Model figures (or ICA as a basis if internal
W orksheets Can I assume, therefore, that Lloyd’s are not expecting the Internal Model worksheets in the QIS 5 models are not developed) to internal model result sheets.
spreadsheet to be filled in by agents?
Investments Sep-10 For all investments we have entered modified duration on the spread helper tab and we are now preparing The duration of assets to be used is the modified duration.
investment holding cashflows to process through the "discounting tool". For Corporate/Treasury bonds we
have no problem. However for mortgage backed securities with a given maturity date in say 20 years which
investment managers have advised a modified duration of say 4 years, should we be entering the cashflow
for this security going out for the
modified duration of four years or the full 20?
MM Funds Sep-10 Can you confirm that MM funds did not require look through and are to be treated as cash for QIS5 I can confirm that you should treat MM funds as cash for QIS5 purposes and look through is not required.
purposes?
OSD's Oct-10 Having had a look at the QIS 5 OSD sheets issued by Lloyd’s last week – they don’t appear to tally up. For When completing the stress tests, we have excluded those assets from the concentration and spread risk which have been issued by or are
example on the Australian Trust Fund sheet the total Government Bonds in cell D8 is different to the number demonstrably guaranteed by a government with a credit rating of AAA-AA and are in domestic currency, as these have no impact on the
in Table 1.1. Another example is that in section 3 – info on spreads, the bonds in the table for Standard SCR. However those Non-EEA domestic government guaranteed assets will need to be included in your submission. Agents will need to
Bonds is different to cell D10. Another example is for the Non-EEA sovereign bonds table – this has only got use the detailed asset data provided to perform their own analysis so as to get the full split of investments.
the amount for the NZ bonds and not the Australian Gov’t bonds (which are surely also non-EEA?) Another
example is in the Australian JATF(2) spreadsheet – the table on Concentration of Assets – the sum of The amount of OSD to be included in the long and short term deposits was that invested in deposits. The OSD should be reported as per
concentration by category for Standard Bonds is greater than the the total Standard Bonds figure. There are the underlying investments.
probably examples like this throughout the other spreadsheets as well. Please advise how to proceed. Also,
as per the Lloyd’s Detailed Guidance, should the OSDs actually be included in long and short-term
deposits?
Overseas deposits Sep-10 If we are applying a look-though basis to the underlying assets, should these be included in the Bonds and Agreed, look through procedures need to be applied on the overseas deposits. The proposal in the QIS 5 guidance to split these between
Cash lines in the Valuation tab, as opposed to the Long / Short Term Bank Deposits suggested in the short and long was meant only for any deposits included in the overseas deposits.
Lloyd’s Detailed Guidance QMA mapping suggests?
Overseas deposits Oct-10 Looking at the split of overseas deposits we have a slight issue. At year end Dec 09 the balance of overseas In the case of the split in the balance sheet, the accrued interest should be presented separately. The accrued interest should be included
deposits accounts was split between deposit and accrued interest. Accrued interest was reported as "other in the "any other assets, not elsewhere shown" line on the valuation tab.
debtor", which is now in other assets on the valuation tab of QIS 5 workbook under current accounting basis.
I now have a choice to either move the accrued interest from other assets under the QIS 5 basis, to ensure
that the sum of Bonds totals back to what was sent to use by yourselves. or leave other assets as originally
reported and bonds will not come back to the statements received. Could you provide some guidance on
which you would prefer to see?
Securities Oct-10 If we have securities that are demonstrably guaranteed by the US Government, where are these placed in the The securities that are demonstrably guaranteed by the US government and are issued in USD should be included in the "Non-EEA
Assets tab in section 3? In the Standard Bonds table or in the Non-EEA sovereign bonds, issued in sovereign bonds, issued in domestic currency" table.
domestic currency table?
Simple/Complex assets Oct-10 Can you clarify for me which assets should be treated as simple and which as complex securitised bonds for Distinction between basic and complex MBS depends on whether the investment provides "pass-through participation certificate " or they
me please, out of: MBS, RMBS, ABS, CMBS, CMOs and ARMs have special features (e.g. protects the investor from certain risks). The pass-through participation certificates entitles the holder to a pro-
rata share of all principal and interest payment made on the pool of loan assets. The complex MBS could be organised in tranches and
each tranche is sold separately. An example of a pass-through MBS include Residential Mortgage Backed Securities (RMBS) and
Commercial Mortgage Backed Securities (CMBS) while example of a complex MBS is the Collateralized Mortgage Obligation (CMO).
"Pass-through" investments should be considered as simple while the collateralized investments should be considered as complex.
Basic own fund items Sep-10 Your instructions say pick up line 11 of form QMA205. What line in Basic own funds items would you expect Members' balance should included in the "Retained earnings including profits from the year net of foreseeable dividends" line
this to appear. It could be either ‘Retained earnings including profits from the year net of foreseeable
dividends’ or ‘Surplus funds’.
Cash deposits Sep-10 Do I treat the collective investment schemes e.g. deposit arrangements as the custodian defaulting or the This should be treated at underlying asset level. Information on overseas deposits was provided to the market 1 October.
underlying assets underneath them. Is there any split of investments available for overseas deposits yet.
Concentration of assets Oct-10 I am in the process of populating the Assets tab on the QIS5 spreadsheet. I am filling in information on Government bonds issued by an EEA state in their domestic currency or in the currency of another member state attract a 0% capital
concentration of assets used for market risk. Currently we have some UK (Govt) stock. Would this be rated requirement. Hence these should not be included in the assessment of market risk.
as standard exposure or non EEA?
Concentration of Oct-10 In the QMA return form 219u we had headings Sovereign Debt , Government Agency and ratings. For QIS5 The terms in the QMA return form 219u are the same as those in QIS5. However, QIS5 requires split of the sovereign debt i.e. those
investments there are Type of exposure and ratings. Is there any views how these should match to 219u? issued by an EEA state, those issued by a Non-EEA state but in its domestic currency, and the rest. Also, there are additional ratings
required under QIS5.
Concentration risk helper Sep-10 Question relates to QIS5 tab SF.SCR.G point 5.104 - Concentration Risk Is the Initial Asset Value total and The concentration risk helper doesn't automatically feed into the QIS5 sheet. I understand that cell F410 of the SCR sheet (labelled
tab Net asset value after shock amount automatically populated from the concentration risk helptab or are these Mktconc) needs to show the value calculated within cell C2 on the concentration risk helper tab (also labelled as MKTconc). You will need
figures manually entered. If manual, what is the shock factor? to input figures to cells F412 and F413 accordingly.
Concentration risk Oct-10 I am assisting in the completion of QIS5 and was hoping you could clarify for me what assets I need to be All assets considered for equity, spread risk and property risk (e.g. corporate bonds, Non-EEA government bonds) should also be
classing and analysing under Concentration Risk and what assets I need to be classing under the considered under concentration risk module.
Counterparty default Risk module. Do you have a definition of what you are expecting to be listed under Assets included in the counterparty risk module include risk mitigating contracts such as reinsurance arrangements, receivables for
each. intermediaries, cash at bank) as well as any other credit exposured which are not covered in the spread risk module.
Refer to CEIOPS Technical Specifications for more details regarding this.
Concentration risk Oct-10 On the concentration risk help tab: a. do we have to group all the US T-Bills together or can we show them a. The US T-Bills can be shown separately.
separately b. for credit default swaps, if these are not included under Solvency II balance sheet then we do b. yes - If the credit default swap are not included in the Solvency II balance sheet, then they should not be included in the currency risk
not need to include them in the currency risk calculation c. is there an error in the pickup on the CEIOPS calculation.
spreadsheet for the operational risk calculation as it only seems to pick up gross direct reserves d. on the c. This was an error in the old version of the spreadsheet. The updated spreadsheet - update no. 3 (dated 28/9/10) picks up the correct
submissions to Lloyd's are Lloyd's expecting questionnaires to be filled out and sent to Lloyd's as part of the balances.
submission? d. Yes, Lloyd's expects the questionnaires as part of the submission.
Contingent liabilities Sep-10 Does the 3% callable New Central Fund contribution count as contingent liabilities? If so , do I need to This would not qualify as a contingent liability under IAS 37. Please see definition of contingent liability in the QIS5 Technical
include it in my QIS 5 Balance Sheet? Specifications, page 17
Counterparty simplification Sep-10 Can you confirm that once I run my SCR calc say 4 times for 4 bands of failed reinsurers and also calculate There are actually two simplifications in use here, the simplified calculation for non-life reinsurance, and the simplification for grouping
the capital cost of failure of banks , intermediaries etc I simply add these numbers together and put in cell counterparties together. It is worth investigating the impact of both, as the use of simplifications is subject to a few conditions about
C18? proportionality (see pgs93-94, SCR1.15-SCR1.23). SCR6.55 also states that the non-life reinsurance simplification cannot be used if it
were to significantly misestimates the risk mitigating effect, or if the result of a more sophisticated calculation is not easily available. From
a few test calcs I have done, the simplified method does significantly misestimate the result so would not be appropriate. Cell C18 (SCR nl)
is just for the impact of non-life RI mitigation on the non-life underwriting risk SCR. Other counterparty exposures sit elsewhere.
Regarding the second simplification, I would check the impact of diversification, as you could have significantly higher charges by
concentrating reinsurance into fewer buckets.
FAL/Overseas deposits Sep-10 Inclusion of FAL in Balance Sheets, Own Fund calculations and SCR calculations. For those Syndicates This information has now been provided to the market.
with a significant proportion of third party capital support, will Lloyd’s be providing us with the breakdown of
the third party capital, into individual stocks including maturity dates, credit ratings, valuation methodologies
etc in order to enable us to run the concentration risk, spread risk calculations etc?
FAL Sep-10 Is the Trust subject to the capital requirements outlined in the market risk module? Yes, in the case of FAL supported by form other than LOC and Bank Guarantee. The amount of FAL that is supported by LOC/Bank
Guarantee is included in the ancillary own fund items (outside the balance sheet) and does not have a corresponding entry in the assets
amount.
FAL Sep-10 How are excess funds taken into account in determining the capital requirements? As per our QIS 5 guidance, page 5, "For a syndicate where all of the capital is provided by a member or group of members participating
solely on that syndicate, please report the full value of FAL held as at 31 December 2009".
The full amount of FAL should be included as assets, however if there is an element of FAL that is supported by LOC/Bank Guarantee, this
should be ignored and it should be included in the ancillary own funds items (this is an off-balance sheet item).
FAL Sep-10 We hold corporate bonds, held in Lloyds trust as FAL. We assume these investments will be included as Corporate bonds held as FAL should be included as assets in the balance sheet and the corresponding entry should be included in the
assets on the balance sheet but are unclear as to where they should be included in own funds tab. Can you basic own funds items. The amount should be included in the "ordinary share capital (net of owns shares) - paid up" line.
please advise?
FAL Sep-10 How should FAL provided in form of cash/investments be treated in the QIS 5 balance sheet? This should be treated as Basic Own Fund items and should be included in the "ordinary share capital (net of own shares) - paid up
capital" line. The corresponding amount should be included in the respective assets lines.
FAL Sep-10 How should FAL provided in form of LOC be treated in the QIS 5 balance sheet? LOCs are treated as Tier 2 capital and should be accounted for in the QIS 5 spreadsheet as Ancillary Own Fund items. The ancillary own
fund amount is outside the balance sheet, hence no amount is included in the assets value. Also as stated in the QIS 5 Technical
Specifications, SCR. 6.45, page 144, "A letter of credit should not be taken into account in the calculation of the counterparty default risk
model if its approved as ancillary own funds".
FAL Sep-10 For FAL cash balances the double entry is presumably Dr Cash Cr Tier 1 own funds. Is this correct? Yes
FAL Sep-10 Is FAL cash allocated to "Initial fund" as opposed to share capital or "other reserves"? This is allocated to the "Ordinary share capital (net of own shares) paid up" line
FAL Sep-10 For the FAL cash balances, (which are a combination of USD and GBP balances), these are presumably Yes
valued at balance sheet rates rather than the exchange rate used in the November coming-into-
line valuation?
FAL Sep-10 For LOC, I think there has to be an associated debit or else the spreadsheet doesn't validate i.e. it doesn't LOC is included in the ancillary own fund items, an off-balance sheet item, and hence no debit entry in the spreadsheet.
balance. Am I mistaken?
FAL Sep-10 As for cash FAL balances, I presumably use the balance sheet exchange rate rather than the Nov CIL Yes
exchange rate?
FAL Oct-10 Following receipt of the advice on the treatment of third party FAL within the QIS 5 spreadsheet (copied The basis you have adopted is correct. The latest advice is relevant for syndicates with third party capital >25%
below), please can you can confirm whether this approach must be followed. In the QIS 5 workshops I seem
to remember it being mentioned that if non-aligned capacity is less than 25% of the total then it would be
acceptable to assume that the asset split of the non-aligned FAL is the same as the aligned asset split.
Hypothecated FAL Oct-10 I have started to populate the CEIOPS QIS5 workbook on a "FAL only" basis so that I have a separate audit LOCs should not have a corresponding asset entry due to the fact that they are an off-balance sheet item. They should only be reflected in
trail of the FAL assets included in QIS5. I have yet to adjust asset values for QIS5, however I have the ancillary own-fund items. We would prefer exclusion of LOC from the presentation of S1 assets and capital.
encountered a couple of issues and would welcome your advice: 1) Valuation tab. I have hypothecated the
non-aligneds' assets using QIS4 as a proxy pro-tem and set the Solvency 1 asset total to the ECA
by inserting the LOC as 'any other assets' at F60 and adding to retained earnings at F118. 1a) I have
excluded the LOCs from 'any other assets' for QIS5 purposes and shown the S1>QIS5 change as a value
decrease. Is this the correct treatment of LOC for Solvency 1 in the valuation tab? 1b) In order to get basic
own funds to work, I've had to insert the LOC value as an adjustment to other liabilities at H125 and deduct
the same value from cell H118. Is this OK? 1c) Would you prefer me to simply exclude LOC from
the presentation of S1 assets and capital [treat as off balance sheet]; i.e. for S1: net assets = ECA
Investment Funds Sep-10 Per page 23 and the additional note on page 24 Investment Funds such as mutuals, should be valued on a Agreed. However you also need to consider any funds that could be included in QMA 2, line 3
look through basis. For current accounting basis the cross reference on the QMA2 is to line 3. However as
at 31.12.09 I do not believe this is where mutuals were put (and the QMA 2 is auto generated). They were on
line 1 on the QMA2 but line 3 on the QMA 201.
Liquidity Sep-10 As at 31/12/09, we held c.€23m in a liquidity fund, which we treated as cash, as it dealt in very liquid paper, Liquidity funds that meet definition of cash and cash equivalent as per IAS 7 should be treated as such. The main factors to consider are:
with a WAL of only 56 days. This was included, along with all our other cash in the trust funds (e.g. LDTF (i) They must be readily convertible to known amount of cash and be subject to an insignificant risk of changes in value. (ii) They must have
etc.), by Lloyd’s definitions, in “Holdings in Collective Investment Schemes” in line 3 on the QMA 201. I was a maturity of 3 months or less from the date of acquisition.
wondering how to treat this on the Balance Sheet – whether to put it as part of cash or whether a look-
through basis should be applied. The issue I have with applying a look-through basis is that the fund
provider cannot provide us with details of the individual holdings or modified durations, but only the % in
each category of rating and asset class (please see attachment), so we would not have sufficient data to
apply a look-through basis – what are your suggestions?
LOCs Oct-10 We have a question on the tiering of letters of credit for the FAL. Lloyd’s QIS5 guidance indicates that LOC/Bank Guarantees are treated as ancillary own fund items and they are Tier 2 capital.
syndicate ancillary funds are made up of letters of credit/bank guarantees (see paragraph 3 on Information
on own funds on page 26). Looking at the corresponding area in the main QIS5 sheet (rows 172 to 174 of
the sheet called “I.Valuation”), it seems that these letters of credit and guarantees can only be tiered into
tiers 2 or 3. We would expect these items to be Tier 1. Could you please state Lloyd’s position on this
issue?
Mapping to QMA Sep-10 I am completing I General spreadsheet (Balance sheet). Your latest detailed guidance states what lines to As confirmed at the recent workshops, agents should use column C.
use from QMA2. For the Assets you say use column A and for Liabilities you say use column C. Is this
correct as we have in our assets items in column c?
Members balances Sep-10 We have a debtor at the year end as we made a loss. Should we include this as FAL as members would have Member debtors would be against syndicate assets rather than FAL and so would not need to be included in FAL. They would be expected
had to increase their funds to meet this loss. to appear in the balance sheet as per the year-end.
Non-life CAT Risk Oct-10 Lloyd’s have stated in the guidance that Lloyd’s “does not expect many syndicates will be able to use the non- Correct. As discussed further on page 16 of the QIS5 guidance, the limitations of method 1 (including not covering non-EEA exposures)
life catastrophe method 1 scenarios given their limitations”. Is the reason for method 1 not being suggested means that Lloyd's will be expecting the majority of agents to perform non-life cat risk calculations using method 2. Please also see
because the “man-made catastrophe” and “natural catastrophe” helper spreadsheets are only applicable for Section SCR.9.171 of the QIS5 technical specifications, detailing that methods 1 and 2 can be combined if required.
European business? Our business is largely non-European so can I assume method 2 would be the
required approach? Am I also correct in thinking either method 1 or method 2 is used and not a combination
of both? Could further clarification be given on the above.
Overseas deposits Sep-10 Overseas Deposit treatment: It has been suggested in the detailed guidance to include the overseas The breakdown of overseas deposits was provided to the market on 1 October to allow for full inclusion.
deposits as long term bank deposits which would fall under counterparty risk. Bearing in mind the
spreadsheet available from the Lloyd's treasury team (as attached) showing the underlying securities; is this
factoring the risk associated at a "better than best efforts" basis? Or should we be including overseas
deposits in the spread and concentration risk helper tab calculations.
Overseas deposits Oct-10 Further to the analysis of overseas deposits into their underlying investments provided a few days ago, I Information on Canadian Margin Fund has already been provided. CILF and CICR are liquidity funds and qualify as cash and cash
understand that the same analysis is required for the Canadian Regulated Funds denominated in USD equivalent, hence no "look through" is required.
which is classed as a holding in an investment pool? Also the Guidance Notes for QIS 5 (page 24, Section 1
“Balance sheet – Assets”) suggest that a “look through” analysis is required for collective investment funds
– would this include the CILF and CICR? If this “look through” analysis is required for these items, is a
“market wide” solution going to be provided as was done for overseas deposits or will we have to get this
information from Citibank/Royal Trust?
Own funds Sep-10 As the syndicate doesn’t have any preference shares, subordinated liabilities or Ancillary owns funds we are This should be left blank if no preference shares, subordinated liabilities or ancillary own funds (e.g. FAL provided in form of LOC/Bank
assuming that the own funds items details tab remaining blank, is this correct? Guarantee).
Own funds Oct-10 We are in the process of completing the QIS5 questionnaire for solo firms and have a question on own "Restricted reserves" is not applicable for Lloyd's.
funds specifically on Restricted reserves per question number 96. What does restricted reserves mean in FIS should be treated the same way as FAL. See FAQ on FAL.
the context of members balance including the closing year distributable profit uncalled/undistributed
losses/profits and Funds in Syndicate ("FIS").
Reserves Sep-10 The QIS 5 technical specification provides the following guidance in respect of "reserves the use of which is We do not consider that the funds which fall within Lloyd's syndicate trust funds should be treated as 'restricted reserves'. The rationale is
restricted":, OF.2.3. Reserves the use of which is restricted OF.12., OF.13, OF.14. Does Lloyd's that the funds are in place to meet reserving requirements, and any excess over and above these are available to meet capital
anticipate that the funds held in trust in respect of Lloyd's syndicates fall within the scope of these requirements.
paragraphs? If so, our initial interpretation is that the amount of the adjustment to own funds will be; The net
value of the syndicate's trust fund assets and related portion of technical provisions, LESS; The element of
the SCR that the net value above could be used for. (The adjustment is nil if this gives a negative number.)
Our concern is that the calculation of the element of the SCR under the 2nd bullet point would be, at best,
complex.
Valuation Sep-10 My syndicate has a reinsurance arrangement with another group company. On the valuation tab in section Section 5 should be left blank given the approach we are taking to completion of QIS 5 i.e. Lloyd's is not a group.
5, can you confirm that I do not need to include this under inter-group balances?
Valuation Sep-10 On the valuation tab in sections 1 and 2 ,did i pick up from the workshop that pipeline premiums should be Future premium cash flows due in the future (e.g. on unincepted business or from future premium instalments) fall within the premium
taken out of reinsurance debtors/creditors and netted off reserves, and is this in the QIS5 presentation provisions under Solvency II. As such, they should not also be included within premium debtors under QIS5 to avoid double-counting. Non
column only or in the first 2 columns? received premium cashflows that are already due would form part of debtors and not premium provisions. If signed premiums are being
used as a proxy for received premiums, then the difference between the two would fall as premium due but not received, rather than future
premiums to be received.
Valuations Oct-10 On the QIS5 spreadsheets I. Valuations tab the column for Solvency I valuation principles and the current The AIM assets count as 'listed'. Please apply 'mark to model' to intercompany and LCA balances.
accounting would you be able to tell me whether AIM investment accounts class as listed or unlisted on the
lines...Equities/other shares (other than participations) – listed. Equities/other shares (other than
participations) – unlisted Also, where we have other assets/liabilities such as intercompany balances and
LCA balances which valuation method would you expect these to be classes as: Mark to Market, Mark to
Model or other?
Cat risk Oct-10 I have two questions regarding the calculation of Cat risk using the factor based method. 1) The Ceiops 1) Apply cat premium 2) allocate a % to each scenario.
guidance says that the premium input Pt = estimate of the gross written premium during the forthcoming
year in the relevant lines of business which are affected by the catastrophe event. (SCR.9.177). We have
developed a model that allocates this gross written premium by SII LoB, which then has the Ct factor applied
to it to produce a gross loss which is then netted down. In the case of something like MAT or NP RI
casualty we are applying the Ct factor to the total GWP for that SII class. Is this correct or should it just be
applied to catastrophe premium? 2) On a similar note, for things like Fire and other damage which is split
into 4 different cat scenarios (storm, flood, earthquake and fire), should all of the GWP have the relevant Ct
factor applied to it or should we allocate a percentage to each scenario?
Non-life CAT risk Sep-10 For the non-life CAT risk, the factors are based on gross written premiums during the forthcoming year per Gross of acquisition costs.
page 242 of the technical specifications. Are gross written premiums gross or net of acquisition costs?
Non-life CAT risk Sep-10 For the non-life CAT risk, the factors are based on gross written premiums during the forthcoming year per Yes, although the assumption that renewals (and therefore unincepted business) will be same at year-end 2010 as for year-end 2009 will
page 242 of the technical specifications. Should the premiums for the 2010 year include 1/1/2011 renewals only hold if premium volumes and mix of business are broadly the same.
which are legally binding at 31.12.2010, as it is on a Solvency II basis? If so, is it acceptable to assume the
business renews the same as for the 2010 renewals?
SCR interest rate Sep-10 On the SCR interest rate risk calculation, I have assumed that the only interest rate risk is to T-Bills and that The interest rate shock should include all assets exposed to interest rates that would include fixed income bonds. There are two reasons.
fixed income bonds do not need to be included in the calculation as they have a fixed income and so would not Firstly, the assets values are included in the balance sheet at market value and hence would move in the event of interest rate "shocks". The
be exposed to interest rate risk, is that assumption in line with Lloyds thinking? second is that the test is completed on Net Asset Value - this is the expected cashflows from assets exposed to interest rates minus
liabilities exposed to interest rates. As all the technical provisions are exposed to interest rates (since they are discounted under Solvency
II) these will be included in the calculation. Therefore by including less assets the interest rate shock may be overstated as the level of
matching could be significantly understated.
SCR interest rate Sep-10 On the SCR interest rate risk calculation, I am taking the asset figure of say £60m for the T-Bills and as The prescribed shocks are on the interest rates not the asset value. The interest risk is measuring an entities net exposure to interest rates
these are all within 1 year I am moving the figure by up 70% and down 75% per the CEIOPS guidance, this (assets exposed to interest rates minus liabilities exposed to interest rates) and the effect on the net present value. For example if the net
gives a large capital requirement. I feel this is not quite right, do Lloyd's have any other guidance for this exposure was 100 payable in 1 years time and interest rates were 1% then the discounted value is 99. If the interest rate shock was 100%
calculation? then the discount rate would be 2% (rather than 1%) and the NPV 98 - I.e. The interest rate risk would be 1 (and not 100).
Definition of PCO Sep-10 For the Geographical split schedule could you define claims outstanding (net PCO) is it the full TP Claims outstanding cash-flow projections relate to claim events having occurred before or at the valuation date – whether the claims
reserve, i.e. including Bad debt and claims handling elements? arising from these events have been reported or not (i.e. all
incurred but not settled claims). The cash-flow projections should comprise all future claim payments as well as claims administration
expenses arising from these events. As per heading in QIS5 spreadsheet, the columns for reinsurance should be net of adjustment for
default. This is the same for the "Net PCO" column in the geographical diversification sheet.
Expected earned Sep-10 Data Item 7 Ref: QIS5 Spreadsheet - Geographical diversification tab, "Next years expected earned written" This item should be your interpretation of next years earned premium relating to all underwriting years (i.e. mainly 2009 and 2010) gross of
column F As per Lloyds guidance this figure (when summed across all QIS5 classes of business and all acquisition costs. 2010 Earned Premium cannot be obtained from the SBF submission, agents may choose to derive an estimate of next
geographical zones) can be taken from the latest approved SBF for 2010. a) We read this figure in the year's earned premium based on their SBF for 2010 however.
SBF to be the 2010 underwriting year net earned premium. Please could you confirm if this is correct. b)
The QIS5 spreadsheet (and CEIOPs technical specifications guidance) suggests the data item required is
the 2010 earned equivalent of data item 6, which we read as the ' calendar year net earned premium for the
2010 calendar year for all years of account'. Please could you confirm if this is correct. c) We understand
that the figure in 7a) would be different from the figure in 7b). Please could you confirm which figure we
should use for the QIS5 spreadsheet.
Geographical Sep-10 We are starting to prepare our data to complete the geographical diversification section of QIS5, does Please see annex M of the CEIOPS QIS5 technical specification for the required mapping.
diversification Lloyd’s have a suggested mapping of which countries / US states belong to each of the 18 regions?
Geographical split Sep-10 At the Lloyd's workshop there was some discussion about how best to approach geographical split and a This is down to the agent but is important that you can justify the approach.
number of agents expressed concern about the difficulty in collating this data. I'm not sure if this discussion
reached any clear conclusion. As an example of the issue, if we have material worldwide business or
business coded to US (but due to current system limitations the extracted data may not show which part of
US) is it legitimate to pro-rate this (potentially overstating diversification benefit) or is it better to allocate to
one particular area (potentially understating diversification benefit). Do you have any advice on which way to
lean or is it purely down to the agent?
IBNR Sep-10 Note on a Solvency II basis claims provisions would include outstanding reserves (case reserves) and This figure should be on a QIS5 basis, not as reported in the QMA. It should be identical (when summed) to section 3 if the QIS5
IBNR reserves but would exclude reserves relating to claims arising from exposures (on contracts existing Insurance Obligations tab (i.e. TP's excluding risk margin).
as at YE09) falling after 31.12.09. It would also include all years of account. It would also include other
adjustments as set out in the Lloyds guidance on technical provisions on a Solvency II basis. c) We
understand that the figure in 8a2) would be different from the figure in 8b). Please could you confirm which
figure we should use for the QIS5 spreadsheet?
I.Premiums Sep-10 Should premiums for the I.Premiums sheet and Geographic Diversification sheet be gross or net of Both Gross and Net premiums should be entered gross of acquisition costs.
acquisition costs?
Net PCO Sep-10 Data item 8 Ref: QIS5 Spreadsheet - Geographical diversification tab, "Net PCO" column H As per Lloyds The net PCO should be agents' QIS5 estimate of technical provisions excluding any risk margin.
guidance this figure (when summed across all QIS5 classes of business and all geographical zones)
relate to the 2009 reporting year. a) We assume that we would take this information (i.e. the total sum) from
QMA returns as at 31.12.09 (i.e. submitted Feb 2010). Please could you confirm if this is correct. a2) We
also read the Lloyds guidance as taking the figure from QMA206 reporting year of account 2009 row 1+2+3
less QMA 203 reporting year of account 2009 row 21+23. Please could you confirm if this is correct b) The
QIS5 spreadsheet (and CEIOPs technical specifications guidance) suggests the data item required is the
net of reinsurance claims provisions on a Solvency II valuation basis as at 31.12.09. Please could you
confirm if this is correct.
Net written Sep-10 Data Item 5. Ref: QIS5 Spreadsheet - Geographical diversification tab, "Net Written" column D As per a) Yes this is correct, please take the 2009 premium as reported in the QMA as at 31.12.2009. The premiums information used should be
Lloyds guidance this is the 'net of reinsurance written premium relating to the 2009 reporting year' (when gross of acquisition costs.
summed across all QIS5 classes of business and all geographical zones) a) We assume that we would a2) Yes, this is correct, this is the same information as reported in a1).
take this information (i.e. the total sum) from QMA returns as at 31.12.09 (i.e. submitted Feb 2010). Please b) Gross less Ceded as reported in the Premiums tab should match that which has been put in the Geographical Diversification tab to meet
could you confirm if this is correct. a2) We also read the Lloyds guidance as taking the figure from the check built in to the premiums sheet, this will be from the QMA.
QMA100 reporting year of account, col: CNV row 5. Please could you confirm if this is correct. b) We also c) No, the information placed in the Premium and Geographical Diversification tabs should relate to the 2009 Reporting Year (i.e. all years
assume that the information required in the QIS5 spreadsheet should match the net figure inferred from of account).
taking item 3 from item 1 above (as there is a check built in the QIS5 spreadsheet). Please could you confirm
if this is correct. c) We understand that the figure in 5.a2) would be different from the figure in 5b) – 5.a2 So the information to be used in the spreadsheet is that reported in the QMA as at 31.12.2009
being on a reporting year basis (2009 only) and 5b being on a calendar year basis (all years of account).
Please could you confirm which figure we should use for the QIS5 spreadsheet.
Net written Sep-10 Data Item 6. Ref: QIS5 Spreadsheet - Geographical diversification tab, "Next years expected net written" The Premiums for 2010 for the Geographical Diversification tab should be your estimate of next years written premium from all
column E As per Lloyds guidance this figure (when summed across all QIS5 classes of business and all underwriting years (i.e. largely 2010 and the unwritten from from 2009) gross of acquisition costs. The SBF may be a useful proxy for this
geographical zones) can be taken from the latest approved SBF for 2010. a) We read this figure to be the but it assumes that the unwritten portion of business at the end of any underwriting year remains relatively stable from year to year.
net written premium for 2010 underwriting year of account supplied in the SBF. Please could you confirm if
this is correct. b) The QIS5 spreadsheet (and CEIOPs technical specifications guidance) suggests the
data item required is the 2010 equivalent of data item 5, which we read as the ' calendar year net written
premium for the 2010 calendar year for all years of account'. Please could you confirm if this is correct. c)
We understand that the figure in .6a) would be different from the figure in 6b). Please could you confirm
which figure we should use for the QIS5 spreadsheet.
USPs Sep-10 I am a little concerned by what “better than best efforts” will be defined as, particularly for the purposes of We are expecting 3 spreadsheet submissions from each syndicate (p.5 of guidance), one of which will have the selected USPs (and no geo
USPs. I think we are OK for the data in methods 1 and 2 of underwriting risk (basically the ultimate at the diversification). There is no requirement to work through all 3 methods, particularly the one(s) for which the data requirement can’t be met.
end of the first year), but I don’t think we would even get close to the data standards required in the QIS5 We are, however, asking agents to explain and justify the chosen method. If you are able to apply more than one method, there may be
technical specifications for method 3. Therefore we are intending to only include the results from one of the benefit in working through both and comparing the results. In the future, the standard formula SCR may be subject to public disclosure; the
first two methods in our submission (Lloyd’s doesn’t stipulate which version of USPs should be used) lower the standard formula SCR, the more favourable balance sheet capital will look in comparison.
depending on which best fits the data. For the reserves, methods 2 and 3 are OK, but we might struggle a
little with the data quality around the inflationary adjustment and margin on O/S claims required in method
1. Therefore we are proposing to be more approximate for method 1 and to focus more on methods 2 and 3.
Please can you confirm that this is acceptable? Note that we will be putting together commentary in the
submission that details the exact data challenges in a bit more detail than the above.
premiums Oct-10 I have a question on the worksheet “I.Geographical Diversification”. According to page 32 of the Lloyd's
detailed guidance the "next year expected" net written and net earned premiums should be taken from our
latest approved business forecast for 2010. Could more clarification be given on this point? The SBF
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Calculation of Sep-10 Under Sections SCR.9.25–9.27 of the QIS5 Technical Specifications, undertakings are allowed to make an If (1) is not possible we still would like agents to attempt something sensible (and explained) similar to (2) so that we can see the impact of
premium/reserve risk adjustment to the gross standard deviation factors to allow for the benefit of non-proportional reinsurance. the non-proportional adjustments. Agents should explain in detail why the approach in (2) has been used. I think (3) is the same as (2), i.e.
SCR.9.27 presents Annex N as the means by which non-proportional reinsurance can be allowed for. Annex a sensible approach that has been explained.
N (and the associated QIS5 helper tabs) require some simple inputs, e.g. Limit and Attachment assuming a
single non-proportional reinsurance contract by Solvency II class of business, with unlimited reinstatements.
It is very unlikely that firms will have in place single non-proportional reinsurance contracts that provide
cover at the level of granularity of the Solvency II class of business. In reality, reinsurance protection will
apply to more granular classes. This, together with simplistic assumptions relating to the structure of the
contract (e.g. single XoL layer, no allowance for proportionality or aggregate deductibles, unlimited
reinstatements etc.) mean that it is unclear how undertakings can allow for non-proportional reinsurance
where these simplifying assumptions are not applicable.
I would further argue that, if only because of the granularity issue, this is likely to be the case for almost
every undertaking). So, my questions are as follows: (1): Is it possible for undertakings to calculate the
Non-Proportional adjustments using alternative techniques, which can then be described in detail in the
qualitative sections of the QIS5 questionnaire? (2): If (1) is not possible, where the simplifying
assumptions are not directly applicable (e.g. where the reinsurance contracts do not exist at a Solvency II
class level), is it allowable for undertakings to calculate parameters based on simplifying assumptions, e.g.
set the input field for the "limit" of the contract to be a volume-weighted average of limits of non-proportional
reinsurance contracts for all the classes that map to the Solvency II sub-classes? (3): If (2) is not possible,
is it the case that undertakings must set the adjustment factor to 100% (i.e. take no credit for non-
proportional reinsurance), or are there other methods that may be adopted? Incidentally, at the QIS5
workshop I attended last week (08/09/2010), Jerome Kirk indicated that (1) and (2)
ought to be possible, but the letter of the law (i.e. SCR.9.27 of the Technical Specifications) seems to
suggest that these are not possible, which would imply that undertakings would set the adjustment factor to
100%, and therefore not take credit for non-proportional reinsurance.
Durations Sep-10 The ‘QIS5 insurance obligations’ sheet of the QIS5 spreadsheet asks for the durations to be input in cells Both the QIS5 technical specification and submission spreadsheet ask for modified duration. It is possible that some of the helper sheets
G134:G172. In the CEIOPS QIS5 manual for completion of the spreadsheets it asks for the modified contain errors and it is worth checking the CEIOPS website for future updates or Q&A responses
duration. However the discounting tool helper spreadsheet seems to calculate the duration. Which one
should we provide?
Expected profits Sep-10 On pages 299-300 of the QIS5 guidance it discusses the expected profits on future premiums. OF.15 says EPIFP is testing the effect of including profits via the future premium cashflows (and whether this should form part of tier 1 or tier 3), so the
expected profits included on future premiums for 'existing (in-force) business' need to be identified own fund item should capture all elements of this. This would include future instalment (or other) inflows due in the future on incepted
separately. Does 'existing business' here mean the same as 'existing contracts' in the best estimate business, premiums on unincepted business, but not premiums that are over-due (which stay within premium debtors and are not moved to
calculations (that is, does it include unincepted contracts to which we have a legal obligation) or is it just premium provisions).
concerned with future premiums on in-force=incepted business?
ECA split Oct-10 I was wondering if I could get some guidance with regards to how to treat the ECA in QIS 5. As at 31/12/09 The proposed approach is correct, apart from the treatment of FIS. FIS should be treated the same way as FAL. Refer to the FAQ on the
my syndicate had c.25% in FAL assets, 25% funds in syndicate, 50% provided by an LOC (half of which was treatment of FAL.
collateralised). By my understanding the FAL assets should go into the QIS 5 asset split (including cash);
the funds in syndicate should go into Basic Own Funds – 1e) Surplus Funds; the full LOC (including
collateralised portion) should go into Ancillary Own Funds Tier 2, Letters of Credit. Please can you confirm
that this is right – if not, what is the right method?
Field definition Oct-10 Attachment point: would this also be called credit enhancement? What is detachment point? Attachment point is the minimum level of losses in a portfolio to which a tranche is exposed, expressed as a percentage of the total notional
size of the portfolio and detachment point is the maximum level of losses in the portfolio to which a tranche is exposed.
Field definition Oct-10 Tenure (years): is this Average life of projected principal or time outstanding since issuance? Tenure means term to maturity of the bond
Gross written premium Sep-10 Data Item 1. Ref: QIS5 Spreadsheet - Premiums tab, "Gross Written" As per Lloyds guidance this is the Yes, this is correct
figure in QMA1 col. A:3. (when summed across all QIS5 classes of business) a) We assume that we
would take this information from QMA returns as at 31.12.09 (i.e. submitted Feb 2010). Please could you
confirm if this is correct. b) In which case we read the data as calendar year gross written premium for
calendar year 2009 (for all underwriting years of account). Please could you confirm if this is correct?
Non proportional Sep-10 Please would you answer the following questions in relation to QIS 5 Annex N – Adjustment factor for non- Lloyd's is asking syndicates to complete the non-proportional adjustment on the prescribed basis if possible. Lloyd's have received a
reinsurance proportional reinsurance for the Non-SLT health and non-life premium and reserve risk sub-modules. This number of syndicates outlining their belief the cacluation is not possible but could be made posssible in applying a numer of assumptions
states in the second bullet that the adjustment factor should only be calculated in relation to per risk excess or simplifications. Therefore Lloyd's are suggesting the following: if a syndicate can complete the calculation "correctly" then they should
of loss reinsurance which complies with the following conditions; it covers all insurance claims that the do so. If a syndicate believes they cannot complete the adjustment exactly as specific then they should apply a reasonable approach to make
insurance or reinsurance undertaking may incur in the segment during the following year; etc; Strict the adjustment "work" but ensure they provide a comment that they have done so including the reason for not being able to complete it
interpretation of this appears to suggest that any reinsurance that does not apply to a whole CEIOPS QIS 5 initially. This will enable Lloyd's to understand the potential quantum/complexity of any issues facing the market and feedback to CEIOPS or
Line of Business (ie does this have to be the definition of “segment”) would need to be excluded. Thus, for the FSA specifically where the adjustment is impractical, impossible or inaccurate. Finally, only Lloyd's central submission will go initially
example, any reinsurance covering specific perils or territories would not be included, and specific marine to the FSA and so the proposed approach will enhance the feedback process rather than stop any potential re-wording if needed.
insurance would not be included for the MAT line of business. ; The phrase “per risk” suggests that per
event reinsurance would be excluded. Please would you confirm that this is the correct interpretation of the
treatment of outwards reinsurance for (a) and (b) as it is likely to mean that a
lot of reinsurance is not included? Point (a) was raised with a representative of the FSA at a recent
seminar, who advised that the QIS 5 specification should be interpreted literally; otherwise there was a
danger that it would not be re-worded appropriately.
Participations Sep-10 In spreadsheet I Participant reporting currency has already been filled in with Euro. We report in Sterling. The currency on line D21 should be changed to the respective syndicates reporting currency. In this case it should be changed to GBP.
What do you want us to change this cell to?
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