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European Insurance and Occupational Pensions Authority

1091

Q&A

Question ID: 1091

Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities

Article: 35

Template: S.06.03

Status: Final

Date of submission: 15 Jun 2017

Question

We have a query regarding the interpretation of the threshold applicable to the reporting of countries under S.06.03:

"For the identification of countries the look-through should be implemented in order to identify all countries that represent more than 5% of the fund being looked-through and until 90% of the value of the fund is identified by country."

Specifically the question relates to countries that represent less than 5% of the total value of a collective investment scheme.  To simplify matters let's assume that there is only one currency and one asset class under the collective.  In these circumstances:

a) Do you require countries to be reported under their specific country code until more than 90% of the collective is allocated to a specific country code?
 
OR

b) Can countries less than 5% be aggregated under the AA code even though that may leave more than 10% of the collective categorised as AA?

An extreme example might help to clarify the question.  If a collective is comprised of 25 countries within the eurozone each representing 4% of the collective would it be correct to report 24 lines of data - 23 under specific country codes (to give 92%) and the 8% balance under the aggregate country code (option a)) or one line of data under the aggregate country code (option b)).

EIOPA answer

The correct interpretation of the threshold application in the one as described in paragraph a) of your question. At least 90% of the amount needs to be identified regarding the specific countries. The code 'AA' cannot represent more than 10% of the amount.

Please note that EIOPA is proposing to amend the Instructions of the template S.06.03 to allow the % referred to be calculated considering the total amount invested in CIU and not by CIU. This amendment does not affect the interpretation above.