Question ID: 1000
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Status: Final
Date of submission: 05 May 2017
Question
Please could you confirm whether all historical data would be restated following a Part VII transfer (transfer of books of insurance contracts)? This would include claims triangles (form 19), claims count (form 20), exposures and claims banding (form 21). There is no indication in the LOG how to treat inward transferred insurance contracts?
If the historical data was not restated would the transferred data be reported as an increase in Case reserves and negative paid?
Similarly on the first submission following the Part VII transfer would the increase in claims count (form 20) only be for those claims transferred?
EIOPA answer
By default in the case of transfer of portfolio an undertaking is to report templates S.19.01.01, S.20.01.01 and S.21.01.01 in the first reporting submission after the transfer as if the undertaking always had the transferred-in business or never had the transferred-out business as the case may.
However, each case needs to be discussed, and preferably agreed, with the specific NSA before the transfer of the portfolio.