Question ID: 1013
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Status: Final
Date of submission: 31 Mar 2017
Question
Recalculated transitionals:
We have a question around how the s.22.05 template should be populated if the transitional were to be recalculated in the future. For row R0010, the LOG file guidance states that following a recalculation, this should be the Day-1 SII technical provisions for obligations existing at the reporting date, valued at the reporting date.
Similarly, for row R0050, the LOG file guidance states that when recalculated this should be the Solvency I technical provisions for obligations existing at the reporting date, valued at the reporting date. However, our interpretation of the recalculation rules is that R0010 and R0050 should be populated with updated values still as at the original reporting date (i.e. Day 1), adjusted to use updated financial information etc.
This in effect avoids “double run-off”, given that there is already the prescribed 1/16th p.a. linear run-off being applied from Day-1, and then also the actual run-off since Day-1 if these fields were instead valued at the reporting date. Can EIOPA confirm that this approach is acceptable?
EIOPA answer
As stated in the Instructions when the recalculation of the transitional deduction takes place, undertakings shall perform the calculations for the obligations subject to TTP, under Solvency I and Solvency II, for business in force prior to 31.12.2015 which still exists at recalculation date. This would mean an up-date of the scope and also using up-dated financial information.
From the moment of the recalculation on a new amount for the 1/16 is defined that this replaces the previous 1/16 adjustment.