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Among others, the CEA strongly opposes the Commission proposal to apply the direct insurance life solvency margin to life reinsurance and supports the consensus reached in the Council to use the direct insurance non-life solvency margin. The CEA also deems the extension of currency matching rules to reinsurers proposed by Article 34 discussed in the Council highly inappropriate.
CEA also opposes the change of the threshold level from EUR 500,000 to EUR 500,000,000 as disproportionately high as it undermines the level-playing field between direct insurers and reinsurers.
EU or Member State provisions dealing with Special Purpose Vehicles (SPVs) should avoid any restriction of the development of alternative risk transfer markets, as they are an efficient way of transferring risks to the capital markets in times of capacity shortage.