On 14 April 2015, EIOPA published a formal opinion (addressed to national supervisors) on certain aspects of the preparation and approval of internal model applications.  The opinion identifies three areas where EIOPA believes that diverging practices/approaches would lead to the inconsistent results and confusion in the sector.  These are (a) modelling of sovereign exposures, (b) absence of certain formal decisions at EU level (e.g. in relation to the risk-free interest rate term structure and third country equivalence) and (c) use of comparative studies in analysing internal models.  The opinion also sets out EIOPA's preferred options/approaches in these respects.