Q&A

Question

I am looking for some further clarity on reinsurance disclosures in S.30.04 and S.31.01, with questions as follows:



S.30.04, C0100 – Share Reinsurer:

This C0100 Share% amount is used to derive both the share of reinsurance premium in C0160 and the share of reinsurer exposure in C0110 (by way of formulae).  This formula application makes sense for reinsurance premium in C0160 as the reinsurance premium amount to which this is applied in S.30.03 C0160 is a pure reinsurer amount.  This formula application only makes for the Reinsurer Exposure in C0110 if S.30.03 C0230 is a pure reinsurer amount (excludes any retention amount).  Two questions please:

- Is this disclosure only required for property / general insurance/ XoL reinsurance, or is this also required for Life reinsurance on Quota Share or Surplus?

- If also required Life reinsurance (on Quota Share or Surplus), is it correct to assume that within S.30.03 “C0230 = (1 – C0200) * C0210” (i.e. S.30.03 C0230 is a pure reinsurer-only exposure amount).



S.30.04, C0170 – Annotations:

The EIOPA Log description is:  "Description of cases where either the reinsurer's participation is at conditions different from those of the standard facultative or treaty placement, or to provide any other information that the undertaking has to bring to the attention of the Supervisory Authority."

However, any reinsurance cases on terms different to those in the treaty will tend to be facultative, where facultative arrangements are out of scope of this QRT (these are reported in S.30.01 and S.30.02 instead).  As such, it is not clear what information you are looking for here in C0170.  Please advise on what disclosures you are looking for in C0170.

S.30.03.01 and S.30.04.01 QRT disclosure ordering:

The ordering of S.30.03.01 and S.30.04.01 is related, with the only difference in row ordering being:

§    - S.30.03.01 includes a Multiline row for those treaties with more than one LoB on different terms (where S,30.03.01 does not include this Multiline row); and

§    - S.30.04.01 includes additional rows where reinsurance exposures are shared between more than one reinsurer.

Given this close similarity of format, I assume you are expecting the ordering between these QRTs to be consistent with each other (i.e. use the same Treaty and Line of Business ordering across both QRTs)?



S.31.01, C0210 – C0230 – External Ratings and Credit Quality Step:

The S.30.04 Log is clear that external rating (and credit quality step) disclosure is not required for Internal Model entities using Internal Model ratings.  However, the S.31.01 Log instruction is not clear on this point.  Can you please confirm that S.31.01 works in the same way (i.e. that external rating and credit quality step disclosure is not required for IM entities using IM ratings)?  This approach would be consistent with the generally-accepted approach for the Asset QRT disclosures.

EIOPA answer

S.30.04, C0100 – Share Reinsurer:

In fact C0230 should be reported for life reinsurance treaties and if not 100% of the amount it should reflect the Limit minus the priority (S.30.03.C0210 – S.30.03.C0190), i.e. excludes retention.



See also Q&A 912.



S.30.04, C0170 – Annotations:



It is the responsibility of the undertaking, that better knows its treaties, to identify any relevant information to include. For example, any limits applicable at the level of the business (outside the treaties).



On-going dialogue between undertakings and NSAs moving forward will facilitate a common understanding of what is expected in this cell.



S.30.03.01 and S.30.04.01 QRT disclosure ordering:

What is meant by "ordering" is not clear. The treaties reported in S.30.03 and S.30.04 should be identified with the same "Reinsurance program code", "Treaty identification code", "Progressive section number in treaty" and "Progressive number of surplus/layer in program". This will allow to identify the treaty in both templates.



This codes must be unique and must be maintained in subsequent reports.



S.31.01, C0210 – C0230 – External Ratings and Credit Quality Step:

EIOPA confirms that the same approach should be followed.