Solvency Capital Requirement (SCR)

EIOPAs response to question 2346 clarified that the 15% type 2 exposure counterparty default risk charge applies to all receivables whether overdue or not overdue. This could also be interpreted as including a charge on bound but not yet incepted business (BBNyI). For example, where premium payment terms are included in the policy and the premium is therefore due. Future premium from BBNyI business is usually included in the technical provisions (Premium Provision). For non-life business, this future premium for BBNyI is shocked under the non-life lapse module (at 40%). Can EIOPA clarify that future premium from BBNyI business should not receive another shock under the Counterparty default risk module?

Clarification request on EIOPA response to Q&A 2346 since the EIOPA response there could be read as requiring future premium from BBNI business to be shocked under the counterparty risk module as well as the non-life lapse risk module. This literal reading may not be what EIOPA intended when responding to Q&A 2236.