Question ID: 102
Regulation Reference: Guidelines on submission of information to NCAs (Preparatory phase)
Article: 35
Template: S.12.01
Status: Final
Date of submission: 20 Aug 2014
Question
County of Underwriting
S.12.01.b
The LOG states that the BEL should be split by "county of the location of the risks underwritten" subject to the Materiality Threshold (of a total of 90% of BEL by LoB regardless of the size of their individual contributions) and always reporting the Home country.
What EXACTLY is the definition of country of underwriting? Registered office of the undertaking? County of sale of business? Country of residence of policyholders? Country of branch through which business transacted?
TP - F3
The LOG provides the following definition: Country where the risk is underwritten.
For TP - F3 BEL is split subject to the Application Threshold (only reporting separately countries whose contribution to TP is in excess of 10% and the balancing countries in one line).
Again, what EXACTLY is the definition to be used here for accuracy and interform consistency?
EIOPA answer
For the purposes of this template and others, “Country of underwriting” means the country where the contract was underwritten, meaning the country of sale of the contract, which will be the country where the product is sold. This is the country of the branch if sold by the branch or country of the FPS registration (host country) if sold under FPS.