July 2022 was a time for Solvency II consultation responses. After responding to EIOPA's rather half-hearted consultation earlier in the month, we also submitted a short response to HM Treasury’s Solvency II review consultation,
As sustainability affects almost everything these days, our UK submission recycled and reused much of the analysis, evidence and explanation we presented the previous week to EIOPA about the need to revisit capital charges applicable to securitised real estate debt under the standard formula; but we also made the case for CRE CLOs as a securitised product that could help channel capital into the upgrading and decarbonisation of existing buildings over the coming years.
Our submission to EIOPA can be seen here.
Our submission to HM Treasury can be seen here.