AMICE argues that CEIOPS paper should distinguish between the following two different situations related to the integration of partial internal models:
1. integrating partial internal model results into the standard formula;
2. integrating standard formula results into the partial internal model: This case should be treated in this consultation paper, where the PIM is close to be a full internal model. In this regard, the undertaking should be allowed to propose alternative methodologies.
Secondly, we agree with CEIOPS that the undertaking should justify the limited scope of its internal model. We also agree that supervisory authorities should retain the power to disagree with the undertakings proposed scope and reject the model, to approve the internal model with conditions and to require the undertaking to submit a transitional plan to extend the scope of the model. However, AMICE members believe that if the internal model is rejected, the undertaking must have the right to appeal the supervisory decision on the limited scope of the partial internal model.
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