3435

We would like to raise a concern regarding the header of table S.27.01.01.19, which currently reads: "Man-made catastrophe risk – Other non-life catastrophe risk." Upon review, we believe this wording is not aligned with Article 119 of the Commission Delegated Regulation (EU) 2015/35. According to the regulation, "Other non-life catastrophe risk" is a sub-module of "Non-life catastrophe risk", not of "Man-made catastrophe risk". In light of this, we kindly request that you review both the header of table S.27.01.01.19 and its corresponding description in the Implementing Technical Standards (ITS) to ensure consistency with the regulatory framework.

Please confirm if our understanding is correct, that the other non-life catastrophe risk submodule covers not only manmade catastrophe risks, but any other risks not modelled under the other 3 submodules of non-life catastrophe risk