Guide LAC DT

The Association publishes its first LAC DT guide, the so-called Deferred Tax ( DT) guide. It is an unfinished document that the Dutch Association of Insurers will adapt, if necessary.

The guide consists of an Excel sheet with formulas. These formulas are an interpretation of the DT rules from Solvency II. The pdf is an explanation of the Excel sheet developed by the Association as a result of DT research by DNB and DNB statements about the DT rules.

The Dutch Association interpretation has not yet been finalised, as discussions with DNB are still ongoing. In addition, the Association still has to validate the Excel sheet with third parties who are not part of the Solvency working group.

DNB has indicated that it will accept any method that it has developed itself that provides a good justification for its compliance with the Solvency II rules. That is why we are publishing this Guide as inspiration for our own DT calculation.

Principles for the treatment of savings mortgages

On 1 September 2021, DNB published a Q&A and a Good Practice on the treatment of savings mortgages under Solvency II for the treatment of savings mortgages . The Association publishes the accompanying Guide with general principles. This concerns the valuation and the way in which the capital requirement is calculated in accordance with DNB's Solvency II legislation and publications. This Guide does not specify the way in which savings mortgages are accounted for (inclusion on the balance sheet and classification) within the accounting principles of the insurer.

The Guide discusses the most common forms of savings mortgages as present on insurers' balance sheets. For other variants, the insurer must carry out an individual assessment.

Review 2020: call for a more balanced proposal for the revision of Solvency II

The Dutch Association of Insurers is calling on EIOPA for a more balanced proposal for amending the European supervisory framework Solvency II. Among other things, the Association argues for measures that better cushion market fluctuations in the value of long-term liabilities. The Association sees no need to adjust the Last Liquid Point (LLP).

Read the full response here.

Review 2018 Solvency II

In June 2019, the Solvency II Delegated Regulation was definitively amended by the 2018 Review Delegated Regulation. However, the previously proposed adjustment of, among other things, the capital requirements for granting mortgages with National Mortgage Guarantee (NHG) will not go ahead, because the capital requirements for banks have been changed by the CRR 3.5 project (Capital Requirements Regulation). This means that, despite earlier expectations, NHG mortgages do not meet the adjusted conditions to qualify as permissible credit protection. As a result, a higher (credit) risk weight will apply to the part of the loan covered by the guarantee.

Repair scheme NHG mortgages

DNB and the Ministry of Finance have promised to use a repair scheme in the 2020 Review to ensure that the NHG mortgages once again comply with the adjusted conditions.

The EIOPA consultation paper on the 2020 Review includes a proposal to add a provisional payment of the expected loss and a counter-guarantee to the current rules for insurers. This regulation will only come into effect once the 2020 Review is completed, which is expected in 2024.

The Association has issued a circular letter about the Review 2018 in which the changes and the entry into force are described.