In the determination of the Solvency Capital Requirements (SCR) within Solvency II the Standard Formula has to strike a balance between risk sensitivity, simplicity and robustness. It is obvious that the Standard Formula does not exhibit full risk sensitivity at every individual company level, as the sensitivity to risks is individually set e.g. through risk mitigation measures the company might have chosen. We welcome the steps taken in the framework directive to promote good risk management and want to encourage the Commission to appropriately reflect the diversity in risk exposure and risk profiles existing in the insurance industry. Solvency II should make use of data and expertise in the industry to the largest extent possible. This could for example be achieved by allowing the use of portfolio specific data in the SCR calculation, as for example for premium and reserve risk (TS.VI.F.5). The CRO-Forum appreciates the progress being made here, but encourages the Commission to expand this approach further to risk sub-modules (see drafting suggestions on VII.A.6. in the appendix).
