Q&A

Question

1.    In S.30.01 the facultative cessions have to be reported while in S.30.03 the treaty ones. Where fac-oblig cessions  have to be reported?

2.    QRT S.30.03 and S.30.04: after the first picture sent in March/April, the undertaking has to send a new submission if material changes have occurred. Is it possibly to defined better “material changes” ? When these changes have to be reported ? How to manage treaties which renewal  is in June ? a new submission has to be sent after the renewal ?

3.    S.30.03 Field C0010, program code. A treaty can belong to more than one program, as for example an XL umbrella covering more lobs (it belong to the marine program, property program,…). How the field has to be filled ?

4.    S.30.04 Fields C0180, C0230, reinsurer and external rating. The undertaking is ceding to a reinsurer without external rating, but the reinsurer’s parent company has a rating. Is it possible to use the rating  of the parent also for the reinsurer (does it depend on the presence of a parental guarantee or any other form of guarantee ?)

5.    In case of a cession to a Lloyd’s Syndicate, as it seems that the LEI code is assigned to the managing agency, what has to be reported ? Please consider that a managing agency can manage more than one syndicate.

6.    S.30.01 Field C0130, sum insured. If the sum insured is unlimited, how the field has to be filled ?

7.    S.30.01. There is a treaty covering 2 lobs (lob 1 and lob 2) at different conditions. In this case 3 rows have to be reported: one for each lob and one for the lob “multiline”. Is it correct to say that on the “multiline” row all the common conditions have to be reported while on the other rows only the different ones ?

8.    Reinsurance premium ceded to the reinsurers has to be reported gross or net of brokerage, if any ?

9.    S.31.01 Field C0100. Is it the sum of fields C0060, C0070, C0080, C0090 ?

10.    S.31.01 Field C0150. Is it the sum of fields C0120, C0130, C0140 ?

11.    S.30.03. There is 1 treaty, life business,  with inception date 01/01/1996 and expiry date 31/12/2015. The parties agree to terminate the treaty with effective date 31/12/2015. The treaty is subject to the Run-off termination clause so the existing policies shall remain in force subject to the term and conditions of the treaty until their natural extinction. Should be reported the treaty in the I EIOPA trasmission FY2016? Because, although any new business will be not covered under the treaty, the reinsurer remains liable for the existing policies. Is this considered as an underwriting risk transfer?

12.    S.30.03. There is 1 treaty, life business,  with the following profit sharing rule:



α (reinsured earned premiums - expenses - reinsurance commissions - incurred claims -losses carried forward)

where it is known only:

α that is based on the number of Lives Reinsured (i.e. < 1000 = 50% ; ≥ 1000 = 70%);

fixed expenses that is equal to 8% of the written reinsurance premium;



What should we indicate in the fields C0330, C0340, C0350 ? Is is possible to leave the fields empty and to report the formula in the annotations field ?

EIOPA answer

1.    As templates are reported from the cedant undertaking perspective a fac-obl should be reported as facultative cession.

2.    It is the responsibility of the undertaking to perform the materiality assessment. If these changes (reinsurance strategy changes materially or the renovation of the reinsurance contracts are performed later than the reporting date and before next 1 January) occur in June, then the re-submission should be done asap after that date, when adequate. Details should be discussed with each NCA.

3.    In this case the program code should be same, and the program needs to be reported in as many lines as needed, in particular one by LoB. Please note that both C0010 (code) and C0070 (LoB) are natural keys of this template

4.    No, the rating of the parent should not be reported. If a rating is not assigned the item should be left blank. The reinsurer should be identified as “9 – no rating available” in column C0250

5.    In this case do not report the LEI code of the managing agency. 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.

6.    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.

7.    In this case you should report only two lines, one for each LoB, reporting the different conditions applied to each LoB. The conditions that re similar need to be reported twice.

8.    It should be reported gross

9.    No, is the result of ceded technical provisions (resulting from claims provision + premiums provision + Non-Life TP calculated as a whole and Life including SLT Health), including the adjustment for expected losses due to counterparty default. The “Non-Life TP calculated as a whole” is not reported in C0060 to C0090.

10.    Yes, please see validation BV164 of List of validations (https://eiopa.europa.eu/Pages/Supervision/Insurance/DPM_Taxonomy_2.1.0_L...)

11.    Yes, this should be reported. C0120 should report 31/12/2015 and in C0080 “Description risk category covered” it should be explained that coverage is only for the run-off business.

12.    The profit commission is expected to be a % of a “reinsurance result”, and it is acknowledge that the formula of this reinsurance result is not fixed. If we understood your explanation correction, the maximum commission is 70% of the result as defined in the contract and the minimum is 50% of the result as defined in the contract, depending on the number of lives reinsured. Our opinion is that in this case C0330 should be 0.7 and C0340 should be 0.5. In C0350 it should be 0.5 or 0.7 depending on the expectation of the number of lives reinsured.