On 5 June 2013, Insurance Europe published a letter sent to the European Commission on 27 May 2013. The letter calls for more appropriate recognition of non-proportional reinsurance (where a reinsurer's liability is not defined for each policy, but is based on aggregate claims incurred by the insurer) under Solvency II and includes certain proposals as to how this might be achieved. The letter suggests alternative methodology to that currently set out under Solvency II for the recognition of such reinsurance. Key concerns identified in relation to the current methodology proposed under Solvency II include the requirement to estimate claim volatility (which can be a challenging task for smaller (re)insurers).