Look-through approach
Requirement to compute regulatory capital on a fund's underlying assets rather than on the units held, to stop a collective wrapper from hiding the real risk.
Treating a fund holding as a single line would let the wrapper decide the capital. Two funds of the same name and value, one invested in sovereign bonds and the other in emerging market equities, would consume the same capital. The look-through approach forbids that. The undertaking must apply regulatory shocks to the fund's underlying assets, line by line, as if it held them directly. Where the detailed composition is unavailable, a grouped approach based on the target allocation is permitted under conditions; the undertaking then takes the most prudent assumption on the unidentified share. Absent any information, the line gets the treatment of type two equities, deliberately punitive. The operational consequence is heavy, and finance departments often discover it late. The manager must supply a detailed inventory at each closing, in a usable format. Vehicles that refuse that transparency are effectively ruled out, whatever their headline return.
Delegated Regulation (EU) 2015/35, in the article devoted to the look-through approach. An insurer holds 200M EUR of units in a fund of funds that publishes its composition only with a quarter's lag. At December 31, it must either obtain an inventory at that date or apply the most prudent treatment. That second option can triple the line's capital charge relative to its actual content.
Look-through approach, look through reporting
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