Can EIOPA please help advise on the correct population of C0040 and C0050 in S.30.03.
1. First question relates to the guidance in C0040 "when the treaty is part of a wider program." which implies that this field is not applicable when the treaty is not part of a wider program, and by extension C0050 probably is also not applicable if c0040 is not applicable.
If there are some general rules that you can impart that would be most appreciated, in addition to this specific cases:
- when a treaty is not part of a wider program (ie for all S.30.03 rows, C0020 = C0010 for said treaty) should C0040 and C0050 by defintion both be 1, or both be left empty? or something else, eg if within the treaty (which in this case represents the entire program) there are different layers, should C0040 in fact be reported (with C0050 representing the total)?
-- please confirm that C0030 is not a consideration for the approach? ie regardless of whether the treaty should or should not be split into different sections the approach for C0040 and C0050 is the same
2. Related to Q1. Is there an expectation that C0040 and C0050 must be the same for all rows of the same treaty ie different rows for the same treaty can not be assigned to different surplus layers of the program? Or no such rule/expectation can be made as different layers within the same treaty can represent different layers of the wider program. Should C0030 be used additionally to represent such cases?
3. Related to Q2. Are there any expectations/rules on the completion of C0040 and C0050 for the "multiline" row in S.30.03? If answer to Q1 is yes then we presume that includes the multiline row. If not, can you advise, where a treaty represents different layers of the program what the "multiline" row for the treaty should show (or should it be blank in this, or all, cases) for C0040 and C0050?
EIOPA confirms that C0030 is not a consideration for the approach; treaties covering different types of reinsurance and different layers of the same program shall be reported in different sections, for instance, C0040 concerning the progressive number and C0050 for the total number of number of surpluses or layers in the same program. Furthermore, if there is no report of a wider program, C0040 and C0050 should be filled with 0.
Please be aware that S30. relates to annual submission and so there is no expectation for Q1 and Q2, unless the reinsurance strategy changes materially after that date or if the renovation of the reinsurance contracts are performed later than the reporting date and before next 1 January. Regarding possible resubmission we would like to refer to Q&A 1536.