Q&A

Question

1. S.30.02 Field C0050, Code reinsurer. If the counterpart has not a LEI code, the undertaking has to provide a specific code. Any rule about this ? The specific code has to be maintained unchanged until the counterpart adopt a LEI code ?

If the counterpart is a pool, it can be reported as single entity only if it is a “legal entity”. Which is the definition of legal entity ?

Please consider that if the single participants of a pool have to be reported, the reported activity is quite difficult as the participants change year by year and of course in the S.31.01 very old cessions have to be reported.

2. S.30.02 Field C0303, external rating. At which observation date has the rating to be reported ? Which is the procedure if the counterpart has not assigned a rating by a nominated credit assessment institution (ECAI) ?

3. S.30.01: one risk can be protected by more than one facultative cession. Are required the 10 largest risks or the 10 largest facultative cessions ? Have the infra-group facultative cessions to be considered in the first 10 to be reported ?                 

4. S.30.01: one risk can affect more than one line of business. This means that it is possible to have the same risk ID in more than one line of business. Correct ?

5. S.30.01: the risk ID has to be unique and shall remain unchanged for subsequent annual reports. If, after some years,  the risk is not anymore existing, can the same risk ID be reused ?

6. S.30.03, field C0010, reinsurance program code: if there is just one treaty belonging to one reinsurance program, has the field to be filled ? If not, how can we connect the treaty protection with the risk in S.30.01 ?

7. Line of business: why there are not present some lobs for Non Proportional reinsurance ? For example “Non Proportional assistance reinsurance”. In which lob this type of cession has to be reported ? The same for Workers' compensation.

8. There are specific rules in order to assign the correct line of business ? For example, which lob has to be assigned to D&O business ?

9. S.30.01: field C0130, sum insured. How has to be reported an unlimited sum insured ?

10. In S.31.01 is it admitted to report recoverables relevant to “unknown” counterparts ? 

EIOPA answer

1. S.30.02 Field C0050, Code reinsurer. If the counterpart has not a LEI code, the undertaking has to provide a specific code. Any rule about this ? The specific code has to be maintained unchanged until the counterpart adopt a LEI code ?

If the counterpart is a pool, it can be reported as single entity only if it is a “legal entity”. Which is the definition of legal entity ?

Please consider that if the single participants of a pool have to be reported, the reported activity is quite difficult as the participants change year by year and of course in the S.31.01 very old cessions have to be reported.

If a LEI code does not exist undertakings have to attribute a specific code. Although there is no specification in the Log, in the cases where a code already exists (eg. national identifier), it is expected that the same code is used as this identifier should be kept consistently over time until a LEI code exist. Legal entity is an entity that has a legal standing in the lies of the law. If the pool is not a legal entity the reinsurers have to be identified.



2. S.30.02 Field C0303, external rating. At which observation date has the rating to be reported ? Which is the procedure if the counterpart has not assigned a rating by a nominated credit assessment institution (ECAI) ?

The date is the reporting reference date (see instructions of C0330). If a rating is not assigned the item should be left blank.



3. S.30.01: one risk can be protected by more than one facultative cession. Are required the 10 largest risks or the 10 largest facultative cessions ? Have the infra-group facultative cessions to be considered in the first 10 to be reported ?

The 10 largest risks are to be reported. If a risk is covered by more than one facultative cession, the column C0040 should be used to distinguish them. A risk might be reported across different rows. Intra-group reinsurance is to be treated equally. A specific template for IGT exists.



4. S.30.01: one risk can affect more than one line of business. This means that it is possible to have the same risk ID in more than one line of business. Correct ?

Correct



5. S.30.01: the risk ID has to be unique and shall remain unchanged for subsequent annual reports. If, after some years, the risk is not anymore existing, can the same risk ID be reused ?

No, the codes should not be re-used.



6. S.30.03, field C0010, reinsurance program code: if there is just one treaty belonging to one reinsurance program, has the field to be filled ? If not, how can we connect the treaty protection with the risk in S.30.01 ?

The field shall always be filed in.



7. Line of business: why there are not present some lobs for Non Proportional reinsurance ? For example “Non Proportional assistance reinsurance”. In which lob this type of cession has to be reported ? The same for Workers' compensation.

The lines of business follow the LoB as defined in Annex I of the Delegated Regulation 2015/35. “Non-Proportional assistance reinsurance” is LoB 28 - Non-proportional property reinsurance, “Non-Proportional Workers' compensation” is LoB 25 - Non-proportional health reinsurance.



8. There are specific rules in order to assign the correct line of business ? For example, which lob has to be assigned to D&O business ?

Assignment of LoB needs to follow description of Annex I of Delegated Regulation 2015/35. D&O (Directors and Officers liability) is LoB 8.



9. S.30.01: field C0130, sum insured. How has to be reported an unlimited sum insured ?

Undertaking should provide an estimation. Please note that the risks to be reported are the ones with the highest reinsured exposure so an estimation needs to be calculated.



10. In S.31.01 is it admitted to report recoverables relevant to “unknown” counterparts ?

No, company needs to know from which entity the recoverables belong. If the counterpart is unknown how will the recoverables be received?