Report on ISVAP's activity for the year 2010

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1 Report on ISVAP's activity for the year 2010

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3 (Law of 12 August 1982, n.576 and subsequent modifications and integrations)

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5 (Law of 12 August 1982, n.576 and subsequent modifications and integrations) Report on ISVAP's activity for the year 2010

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7 PRESIDENT - DIRECTOR GENERAL Dott. Giancarlo GIANNINI BOARD OF DIRECTORS Dott. Luigi FABBRI Rag. Gabriele FRIGATO Avv. Antonio MAROTTI Dott. Mario MASINI Prof. Mario MUSTILLI Dott. Luigi SAPPA DEPUTY DIRECTOR GENERAL Dott.ssa Flavia MAZZARELLA Confirmed by presidential decree of 20 June Appointed by decree of the President of the Council of Ministers on 20 July 2009.

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9 Indice Generale I - THE INSURANCE MARKET Undertakings operating on the market The premium portfolio The premium portfolio in life business The premium portfolio in non-life business Market concentration Premium income based on shareholdings and on the main activity of the parent group Market globalisation The financial position and the solvency margin The financial position: assets - the investments Representative assets The portfolio of debt securities The financial position: liabilities and equity The solvency margin The progress achieved in the economic financial management Life business Non-life business Motor vehicle liability and liability for ships (sea, lake and river and canal. vessels) Motor vehicle liability direct compensation The other non-life insurance classes...25 II - THE EVOLUTION OF THE SECTOR The evolution of the international framework The activity of international bodies The peer reviews of the Financial Stability Board in the insurance sector The reform of European supervision and the evolution of European legislation The reform of the supervisory architecture The other measures issued Legislation in preparation and current trends Activity within EIOPC (the European Insurance and Occupational Pensions Committee) Activity within EFCC (the European Financial Conglomerates Committee) Activity within CEIOPS Cooperation between level-3 Committees (CEBS, CESR, CEIOPS) and activity within. the Joint Committee on Financial Conglomerates (JCFC, former IWCFC) The national regulation The new laws Provisions issued by the Authority Regulations issued by the Authority in implementation of the Insurance Code Draft regulations implementing the Insurance code Other ISVAP measures with general content Initiatives in the field of motor liability...46 III - COLLABORATION AGREEMENTS WITH OTHER AUTHORITIES Identification of financial conglomerates Coordination agreement between the Bank of Italy, CONSOB and ISVAP on the application. of the IAS/IFRS Cooperation with the Bulgarian Authorities...49

10 IV - THE SUPERVISORY ACTIVITY Off-site supervision Technical, financial and assets/liabilities controls over insurance undertakings Internal funds and segregate funds Checks on technical provisions Internal control systems and risk management Internal models: their pre-application Shareholdings, participations and intra-group transactions Shareholdings Participations Intra-group transactions Cross-border groups Financial conglomerates Authorisations to insurance business and extraordinary operations Authorisations and extensions Extraordinary operations Supervision over products and contract disclosure Life assurance products Life assurance products Supervision of foreign undertakings licensed to pursue business in Italy under the. right of establishment or the freedom to provide services Supervision over unauthorised or not licensed intermediaries, both Italian and foreign Inspections On-site inspections Technical provisions Financial management Underwriting of risks Anti money laundering Claims settlement procedures Intermediaries and other operators...81 V - CONSUMER PROTECTION ISVAP s interventions for the protection of users Initiatives for the benefit of consumers The motor liability insurance quotation service for consumers The Check Box project The Claims Data Bank Termination of contracts - Guidelines to the undertakings Investigation on motor vehicle liability settlement structures Complaints Complaints about non-life insurance Categories of complaints about non-life insurance Complaints about life assurance Territorial origin Telephone line Complaints register kept by insurance undertakings Information Centre...93 VI - INSURANCE INTERMEDIARIES AND LOSS ADJUSTERS The Single Register of insurance and reinsurance Intermediaries Registered intermediaries The national Register of loss adjusters Supervision over insurance intermediaries and loss adjusters...96 II

11 VII - SANCTIONS Pecuniary administrative sanctions Sanctioning proceedings initiated Types of violations The ordinances issued The sanctions paid Disciplinary sanctions Activity carried out by the Guarantee Committee Types of sanctioned violations VIII - LEGAL ADVICE AND LITIGATIONS Legal advice Litigations IX - WINDING UPS Administrative compulsory winding up Ordinary winding ups X - STUDIES AND STATISTICS The study activity Statistics Insurance education XI - ISVAP S ORGANISATION Staff Training of staff Internal Auditing IT systems Chart XII - STATISTICAL TABLES III

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13 Statistical Tables A Tables pertaining to the Italian insurance market: page Tab. 1 Tab. 2 Tab. 3 Tab. 4 Undertakings pursuing insurance and reinsurance business in Italy Premiums of the Italian direct insurance portfolio Premium incidence over the gross domestic product Insurance business pursued abroad by Italian undertakings and in Italy by foreign. undertakings Year Tav. 5 Market shares by groups Italian direct insurance portfolio years Tab. 6 Outward reinsurance premiums Life and non-life business year Tab. 7 Tab. 8 Tab. 9 Tab. 9.1 Tab. 9.2 Loss ratio non life business Balance sheet life and non-life business Profit and loss account life and non-life business Breakdown of the profit or loss for the financial year life business Breakdown of the profit or loss for the financial year non-life business Tab. 10 Share capital, capital provisions, solvency margin life business Tab. 11 Share capital, capital provisions, solvency margin non-life business Tab. 12 Tab. 13 Tab. 14 Tab. 15 Investments life business Investments non-life business Life assurance provisions Non-life insurance provisions Tab. 16 Assets representing life insurance technical provisions Tab Assets representing technical provisions pertaining to unit and index-linked. contracts Tab. 17 Assets representing non-life assurance technical provisions Tab. 18 Tab. 19 Consolidated accounts balance sheet Consolidated accounts income statement V

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15 The Insurance Market I - THE INSURANCE MARKET 1. - Undertakings operating on the market Undertakings and foreign branches subject to ISVAP s supervision Italian undertakings 151 of which: Life 61 Non-life 76 Composites 14 Branches of non-eu undertakings 2 TOTAL 153 Undertakings and foreign branches subject to home country supervision Undertakings writing business under the freedom to provide services As at 31 December 2010 the undertakings authorised to pursue insurance and reinsurance business in Italy under the supervision of this Authority were 153 (159 in 2009), 151 of which were national undertakings (156 in 2009) and 2 branches of undertakings with head office in a non-eu country (3 in 2009). Of the domestic undertakings, 61 pursued only life business, 76 only non-life business and 14 were composite undertakings. During 2010, 4 domestic undertakings (3 pursuing non-life insurance and 1 pursuing life assurance) were authorised to pursue insurance business. During the same period 9 undertakings ceased business, 5 of which pursued non-life insurance (2 as a result of mergers by incorporation, 2 as a result of winding-up proceedings and 1 as a result of a portfolio transfer whose effects started from 1st January 2011) and 4 pursued life assurance (all of them as a result of incorporations). Moreover, as at 31 December 2010, there were 82 branches of undertakings with head office in another EU member State (20 in life assurance, 53 in non-life insurance and 9 composites) carrying on business in the Italian territory under the right of establishment, while 959 undertakings with head office in a EU member State or in another country of the EEA (European Economic Area), were licensed to pursue business in Italy under the free provision of services, also through establishments within the EU: 174 of which in life assurance, 732 in non-life insurance and 53 composites. 36.6% of the branches licensed to pursue business on the Italian territory had their head office in the United Kingdom, 18.3% in France, 11% in Germany and 13.4% in Ireland, while the remaining percentage was spread across undertakings with head office in Austria and Luxembourg (4.9%), Belgium (3.7%), Spain and Netherlands (2.4%), Liechtenstein and Denmark (1.2%). Of 959 undertakings writing non-life business into Italy under the freedom to provide services 18.9% were based in the United Kingdom, 13.1% in Ireland, 10.4% in Germany and 9.3% in France. The remaining 48.4% was spread across undertakings with head office in the other EU and EEA countries, in particular in Luxembourg, Austria, Belgium, Sweden and Spain. As regards life business 21.3% of the undertakings licensed to write services business into Italy had their head office in Luxembourg, 18.4% in Ireland, 17.2% in the United Kingdom and 11% in Liechtenstein. The remaining 32.1% was spread across undertakings with head office in other EU and EEA countries, in particular in France (9.8%) and Germany (8.6%). 1

16 ISVAP Report 2010 The 53 composite undertakings were based mainly in Austria (37.7%), France (13.2%), United Kingdom (11.3%) and Belgium (9.4%). The remaining 28.4% was spread across undertakings with head office in other EU and EEA countries, with the highest proportions in Spain (7.5%). In 2010, 61 new undertakings were authorised to pursue insurance business by way of freedom to provide services mainly based in Germany (17), France (11), United Kingdom (5), Spain and Gibraltar (4). Finally, the number of branches of specialist reinsurance undertakings with head office in the EU remained unchanged compared to 2009 (7) The premium portfolio Gross premiums written in financial year 2010 Premiums of the Italian direct insurance portfolio In 2010 gross premiums written of the Italian and foreign portfolio were 129,089 million euro, with an increase of 6,9% 1 compared to 2009 (120,727 million euro). Premiums of the Italian sole insurance and reinsurance portfolio amounted to 127,225 million euro (119,132 in 2009) and represented 98.6%of the whole market. Compared to 2009, the premium income of Italian direct business increased to 6.9% (+28% compared to 2009): the premium income of non-life business was equal to 35,852 million euro (-2.3% compared to 2009), in life business was equal to 90,102 million euro (+11% compared to 2009). 1..The insurance market trend for 2010 was analysed by comparing the provisional balance-sheet data with the balance-sheet data for

17 The Insurance Market Premium income - Years 2009 and 2010 compared on homogeneous bases The changes in the premium income were significantly influenced by the exit from the Italian direct portfolio of a domestic undertaking and of the Italian branch of a non-eea country. The same variations re-calculated on homogeneous bases (in other words excluding from 2009 data the two undertakings premium income exited in 2010) make clear an increase in the overall Italian direct business (life and non-life) and of the sole non-life classes equal, respectively, to 8.4% and to 2.1%. The following table shows, under equal conditions, the variation in premiums written for single non-life classes. Non-life business variation (%) on homogeneous bases Accident -0,6 Sickness 3,2 Land vehicles -1,2 Railway rolling stock -8,6 Aircraft -1,2 Ships (sea, lake and river and canal vessels) -3,o Goods in transit -2,8 Fire and natural forces 3,6 Other damage to property 1,8 Land vehicles liability 4,5 Aircraft liability 4,8 Ships liability (sea, lake and river and canal vessels) 5,4 General liability -3,0 Credit 10,9 Suretyship 0,6 Financial loss -14,7 Legal expenses 2,3 Assistance 5,4 Total 2,1 The premium income of non-life business had a 28.5% incidence on overall business, in life business was equal to 71.5% (in 2009 they were 31% and 69% respectively). Premium over GDP ratio The incidence of motor insurance (motor vehicle liability and land vehicles) was 15.8% of the total market, and 55.6% of the non-life sector (respectively 17.1% and 54.8% in 2009). In 2010, the ratio between the premiums of the Italian direct portfolio and the GDP continued to grow and reached 8.1% (7.7% in 2009). 3

18 ISVAP Report 2010 Outward reinsurance 2010 Plans of cessions... reinsurers From the examination of the plans of reinsurance cession sent by undertakings, it came out that 9 undertakings out of 160 did not envisage to avail themselves of reinsurance for The plan of cessions was based on the assumption of gross premiums written equal to around 105,400 billion euro (65% of which pertaining to life business), considerably lower than the actual business for Undertakings envisaged to cede 4.8% of the estimated gross premiums written in reinsurance, i.e. 5,052 billion euro (+3.8% compared to 2009; premiums relating to direct insurance + premiums relating to reinsurance, including intra-group reinsurance); 27.5% of them are related to life business, 72.5% to non-life business; 23.4% was ceded via an intermediary and 76.6% ceded directly to reinsurers. With reference to the instrument used: proportional treaties 3,650 million euro of premiums (93% of which from direct business); non-proportional treaties 570 million euro (96% of which from direct business); optional reinsurance 832 million euro (65% via a reinsurance intermediary, less than 5% related to life business). Furthermore 59.6% of the total premiums ceded (direct insurance and reinsurance) is thus subdivided: Class 1 Human life (25.8%), Class 9 Other damage to property (12,2%), Class 8 Fire and other natural forces (9.5%), Class 13 Motor liability (6.2%) and Class 10 general liability (5.9%). In 2010, 454 insurance and/or reinsurance undertakings were used as reinsurer: they were broken down as follows based on the territory: 305 EEA insurance undertakings, to which 4,184 million euro of premiums were ceded (equal to 82.8%); among them 39 undertakings having their head office on the Italian territory; 149 undertakings having their head office outside the EEA (868 million euro of premiums, equal to 17.2%). In absolute terms the top 5 reinsurers working on the Italian market earned 40.2% of the premiums ceded. 4

19 The Insurance Market intermediaries Reinsurance mediation undertakings which pursued business on the Italian market were 74, 63 of which pursuing optional reinsurance and 31 reinsurance under treaties. They can be broken down as follows based on the territory: 67 belonging to the EEA, which mediated 1,181 million euro of premiums, equal to 23.4% of the total ceded premiums; 26 of them having their head office on the Italian territory; 7 undertakings having their head office outside the EEA. (3 billion euro of premiums, equal to 0.1% of the total premium ceded). In absolute terms the top 5 intermediaries working on the Italian market earned 17.4% of the premiums ceded, and they have all branches and/or head offices on the Italian territory The premium portfolio in life business Income by classes In 2010, the premium income of life business registered an increase equal to 11.1%, confirming, although in a less consistent way, the growth registered in 2009, in which the premium income registered an increase of 48.7%. Although in 2009 class I products spurred the life income recovery (+106% compared to 2008, +4.8% in 2010), in 2010 the increase in the sector was mainly due to class III products, whose income increased by 58.3% (-47.6% in 2009). Class V registered a slight increase (+1.5%), which represents a significant downsizing compared to +58.9% registered in 2009 (-28.5% in 2008). The data analysed show an increase of investments in products with higher financial content, which are potentially more profitable, differently from the previous period in which investments were made in products with a guaranteed capital and/or minimum return. Also in 2010, the stability of the claims burden over premiums and surrender over premiums ratios, which reached 74% and around 40.5% respectively (70% and 39% in 2009), accompanied the positive trend of the premium income. The products of class VI were 1.9% of the total life income (as in 2009). The positive trend registered a further slowdown (+9% compared to 2009; +13.5% compared to 2008) after the two years of growth due to the entry into force of the reform of pension schemes (+88% in 2008 and +152% in 2007 respectively). 5

20 ISVAP Report 2010 Life products distribution channels... banks and post offices... financial promoters...agencies...other forms of sales As to insurance products distribution, banks and post offices represented, also in 2010, the main distribution channel used (60.3%; 58.8% in 2009), although with an income increase (+16%) lower when compared with 2009 (+64%). The income of class I products remained almost unchanged in 2010 (60.9%, 60.8% in 2009), while the distribution of class III products showed a significant increase (69.5%, 57.8% in 2009). The percentage of life assurance products distributed by financial promoters slightly decreased (15.8% in 2010; 16.3% in 2009) with a 9.8% increase in premiums compared to the previous financial year. A slight decrease affected the distribution through agencies (22.6% in 2010, 23.7% in 2009); the income of class I products remained stable (22.8% in 2010, 22.7% in 2009), and the unit and index linked products distribution decreased to 5.4% in 2010 (10.3% in 2009). Finally, the slight increase in the income through other forms of direct sale and brokers is worth mentioning (about 1.4% in 2010; about 1.2% in 2009). 6

21 The Insurance Market The premium portfolio in non-life business 2010 income Distribution channels in non-life business From the insurance non-life market trend in 2010, it came out that there was a decrease of the total income equal to -2.3% (-2% in 2009), while motor insurance was constant (-3.5% in 2009). The variation, calculated under equal conditions, shows an increase by 2.1% for the non-life business and by 4.5% for motor insurance. As to distribution in 2010, agencies remained constant with an income equal to 84.4% (85% in 2009, 86.4% in 2008), while brokers distribution decreased (8% in 2010, 8.4% in 2009). Banks and financial promoters registered a 3.5% increase in the income (2.7% in 2009); the same for other forms of direct sale which reached 4.1% (3.9% in 2009). 7

22 ISVAP Report Market concentration Concentration index...by groups...by undertakings In 2010 the degree of concentration 2 by groups, calculated on premiums earned, showed a decrease, with a concentration ratio of the top 5 groups equal to 49.7% of the market (52.6% in 2009), while the top 10 groups held 74.9% (76% in 2009). In life business the share held by the top 5 groups was 53.2% (56.2% in 2009), while for the top 10 groups it was 76.6% (79.2% in 2009). In non-life business the market shares registered by the top 5 groups increased (68.3% in % in 2010), while for the first 10 groups it remained at 85.8% (85.7% in 2009). The top 10 life undertakings collected 55.5% of premiums (57.5% in 2009), while the share held by the main 10 non-life undertakings was equal to about 67.1% (66.8% in 2009) Premium income based on shareholdings and on the main activity of the parent group. Premiums by ultimate parent company s nationality: - State and Italian public bodies - Foreign entities - Italian private entities... of which: based on the main activity of the parent group In 2010 the income related to undertakings controlled by the State and Italian public bodies had an impact on Italian direct insurance portfolio equal to 8.3% (6.8% in 2009). The income earned by undertakings controlled by EU foreign entities remained almost unchanged (19.7% in 2009, 19.3% in 2010); for the companies controlled by non EU entities the income remained almost unchanged (1.6%). Branches of non-eu undertakings showed a decrease, and stayed at 0.3% only (about 1.5% in 2009). The premiums earned by undertakings controlled by Italian private entities increased from 68,442 million euro in 2009 to 77,357 million euro in 2010 (+16.5%); the incidence over the Italian direct portfolio was 61.4% (58% in 2009). In particular, the share attributable to subjects belonging to insurance groups further declined (77.6% in 2..n cases of participations on a 50/50 basis premiums are subdivided at a rate of 50%. 8

23 The Insurance Market ; 84% in 2009, 89% in 2008), while that related to banking and financial groups recorded a significant increase from 16% in 2009 to 22.3% in 2010; the industrial and services sector s income was negligible. Going into details, the premium income from life business collected by undertakings controlled by insurance groups showed a further decrease, and went to 68.6% (77.5% in 2009), while premium income of banking and financial groups increased also in 2010 reaching 31.4% (22.5% in 2009). In non-life business the premiums earned by undertakings controlled by insurance groups remained constant (96% in 2009, 96.5% in 2010), while undertakings controlled by banks and financial groups slightly decreased (from 3.9% in 2009 to 3.4% in 2010). - Undertakings owned on a 50/50 basis by banks and insurance companies The premiums earned by undertakings owned on a 50/50 basis by banks and insurance companies, both Italian and foreign, showed a significant slowdown with 11,410 million euro (14,454 million euro in 2009) equal to 9% of the Italian direct portfolio. In this segment, while the foreign insurance undertakings with their head offices in the EU showed in absolute terms an increase of 12.4%, with an income equal to 10,814 million euro (9,624 in 2009), Italian insurance undertakings significantly dropped in their income (0.595 million euro in 2010, 4,830 million euro in 2009) Market globalisation Business pursued abroad by Italian undertakings premiums earned by foreign undertakings controlled by Italian undertakings premiums earned by branches and by way of freedom to provide services (excluding foreign subsidiaries) In 2010 the total premiums earned abroad (EEA and non- EEA countries) was equal to 62,090 million euro (61,015 million euro in 2009); 86% of them related to direct business. The premium income from direct business earned abroad by foreign subsidiaries of Italian undertakings was 96% of the total, and went from 52,182 million euro in 2009 to 52,958 million euro in In particular, in ,555 million euro of premiums were earned in the country of the head office and 6,403 million euro under the freedom to provide services - the latter were wholly written in Italy in life business. Reinsurance premiums collected by controlled undertakings went from 6,775 million euro in 2009 to 6,816 million euro in the last financial year. The premiums collected abroad (direct and indirect business) through head offices and branches of Italian undertakings were equal to 2,315 million euro (2,058 million euro in 2009); 577 million euro of them were related to direct business (590 million euro in 2009) and 1,739 million euro to indirect business (1,468 million euro in 2009). 52% of the premium income (direct and indirect business) was realised in the EEA countries, and 56% of it was life business. 9

24 ISVAP Report 2010 premium income within the EEA... under the right of establishment... under the freedom to provide services... premiums earned in non-eea countries Premiums earned in Italy by foreign undertakings (FOS excluded) Within the EEA only one branch of Italian composite insurance undertaking carried on business (two in 2009: one non-life and one composite), while as in the previous financial year the number of undertakings carrying on business under the freedom to provide services was 24, 8 of which pursuing non-life business, 4 life business and 12 composites. Going into details, the income collected by way of establishment in the EEA was 349 million euro; 86% of them related to non-life business. The activity (direct business) pursued within the EEA regarded exclusively the United Kingdom in life assurance, while in non-life insurance the main income was collected in Portugal (77%), followed by United Kingdom (22%). The income collected by way of free provision of services amounted to around 850 million euro, with an incidence of life products of 70%. As regards the localisation of business, life business (direct business) was mainly located in France (33%), then in Spain (24%), United Kingdom (14%) and Germany (13%). In the non-life sector premiums were mainly collected in Germany (16%), United Kingdom (14.5%), France (14%) and Greece (13%). Within the non EEA countries, 3 branches of Italian undertakings, as in the previous financial year (1 non-life, 1 life and 1 composite), and 20 undertakings carried on business under the freedom to provide services in 2010: 6 non-life, 7 life, 7 composite (18 in 2009: 6 non-life, 4 life and 8 composite respectively). The relevant premium income was a total 1,117 million euro (241 million euro in direct insurance business and 876 million euro in reinsurance). In 2010 the branches of foreign undertakings and the Italian subsidiaries of foreign undertakings collected in Italy premiums from direct insurance for 37,607 million euro, equal to 30% of the Italian direct portfolio (37,189 million euro in 2009). More specifically, the incidence on the Italian direct portfolio collected by Italian undertakings controlled by foreign entities amounted to 21% (21.3% in 2009), while the branches of EEA undertakings showed a decrease (from 3% in 2009 to 1.9% in 2010) of Italian direct business. Finally, the non-eea countries which have collected premiums through their branches in Italy only in non-life insurance (direct insurance) showed a decrease from 1,778 million euro in 2009 to 355 million euro in The financial position and the solvency margin Due to the persistent exceptional turmoil in the financial markets, by Decree Law No. 78 of 31 May 2010, on urgent measures 10

25 The Insurance Market for financial stability and economic competitiveness, converted by law No. 122 of 30 July 2010, some extraordinary accounting measures enacted in 2008 through Law 2/2009 were repeated. Consequently, the option given to undertakings to use an optional system of transitional nature for the evaluation of the financial instruments classified as current assets, was extended to financial year the undertakings which have made use of Regulation n the gross not available provision and the one net of tax charges... the instruments involved in the non depreciation... impact on the accounting margin... impact on the assets representing technical provisions In 2010 the total number of the undertakings which used this option increased compared to 2009, while the amounts subject to the optional system decreased. Going into details: the undertakings involved were 25 (15 life; 10 non-life), the groups were 10, for a total market share equal to 17% of the Italian direct portfolio premiums income (2009: 9 undertakings, 3 life, 4 non-life and 2 composites, with a market share of 10%); the gross not available provision was 230 million euro (511 million euro 2009), 199 million euro of which in life sector; EUR 30.9 million in non-life sector. The not available provision, net of tax charges, was about 161 million euro (363 million euro in 2009), 138 million of which were related to the life sector and 22.7 million euro to the non-life sector. It consisted of 5% profits, 85% available profit provisions and 10% profits of subsequent financial years. The non depreciation refers for 92.8% to bonds and to other fixed-income securities (92.2% in life assurance; 96.3% in non-life insurance); for 7.1% to undertakings shares and units (7.7% life and 3.4% non-life) and, with a minor impact, to the investments in units in unit trusts (0.4% non-life, 0.02% life). To calculate the available solvency margin undertakings used an amount equal to about 124 million euro (about 346 million euro in 2009) respectively 0.4% of the available life solvency margin (0.9% in 2009) and 0.02% of the available non-life solvency margin (0.5% in 2009). The non-depreciation s impact on assets representing technical provisions was 98.7 million euro (496 million euro in 2009), about 0.03% of the life and non-life technical provisions. The values shown hereinafter in the report take into account the effects of the anti-crisis measures, except for specific indications The financial position: assets - the investments Investments of the life and non-life insurance market (item C+D)... At the end of 2010, the total insurance market investments (excluding reinsurance undertakings) were equal to million euro; (2009: about 489,479 million euro), with an increase equal to 5.6%. 11

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