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European Insurance and Occupational Pensions Authority

1093

Q&A

Question ID: 1093

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

Article: 35

Template: S.29.03

Status: Final

Date of submission: 03 Apr 2018

Question

I've been filling out S.29.04 and I have a few questions:

-    The first question is, should we be able to reconcile the totals in R0070 of S.29.04 to anything in S.29.03? The way it is set up, I think we should be able to reconcile to cell R0360/C0120 in S.29.03, however the current approach given in the log file means this doesn’t work.

-    Assuming we should be able to reconcile – why is C0020/R0040 in S.29.04 restricted to pick up solely C0010/R0070 and C0020/R0070 from S.29.03? The row R0040 in S.29.04 is headed “Variation of Best Estimate”, which should surely contain everything in S.29.03 between rows R0020 and R0110; R0060 is risks accepted during the period, the rest is movements in risks accepted prior to the period.

-    All the other rows can be reconciled:

o    R0010 in S.29.04 matches R0310 in S.29.03
o    R0020 in S.29.04 matches R0320 in S.29.03
o    R0030 in S.29.04 matches R0330 in S.29.03
o    R0060 in S.29.04 matches R0300 in S.29.03

-    There is only one further exception; we need to populate R0050 with the movement in Risk Margin so we can reconcile exactly. R0360 in S.29.03 is the total movement in technical provisions, whereas all of the movements in S.29.04 so far are movements in best estimate.

I would like to be able to illustrate this with a table containing my proposal, but this form does not allow for that. Is there an email where I can contact you with my suggestions?

EIOPA answer

Your analysis is partly correct. The following rows can be reconciled:
o R0010 and R0080 in S.29.04 matches S.29.03.R0310;
o R0020 and R0090 in S.29.04 matches S.29.03.R0320;
o R0030 and R0100 in S.29.04 matches S.29.03.R0330;
o R0060 and R0130 in S.29.04 matches S.29.03.R0300 (but please see new meaning).
S.29.04.R0040/R0110 does not reflect the total variation of the best estimate. Please see clarification above and the proposed proposal to correct/amend Instructions to be published by end of March.

Regarding the Risk Margin, the amount should not be reported in S.29.04. The same applies for the amount of transitional on technical provision.