Question ID: 1094
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Topic: Reporting Templates
Article: 35, 212
Template: S.06.03
Status: UnderReview
Date of submission: 19 Apr 2017
Question
The General Comments to the QRT 06.02 - List of assets defines the scope of this QRT as following:
"This template contains an item–by–item list of assets held directly by the group (i.e. not on a look–through basis)….".
My questions:
1- Does the definition of the group in the meaning of Article 212(1)(c) of Directive 2009/138/EC includes collective investment undertaking (CUI) or in my case a german Spezial-AIF?
2- In case of that an UCIT belongs to a group, is it expected, that a look-through has to be made and the investments within/inside the CUI/spezial-AIF have to be reported in 06.02 - List of assets?
3- Or do you expect every information about CUI/spezial-AIF to be made only in the QRT S.06.03 – Collective investment undertakings – look–through approach?
We are approaching difficulties with our investment managers (more than one KAG) to get sufficient information to comply with the reporting requirements within 06.02/ 07.01/ 08.01/ 08.02.
Most of the Investment-Managers/ KAG/ Zentralverwaltungsstellen are only willing to deliver Solvency-II-Data in the TPT-Format which does´t contain all the infomation of 06.02/ 07.01/ 08.01/ 08.02.
EIOPA answer
Collective investment undertaking (CUI) is also included in the definition of an insurance group in the meaning of Article 212(1)(c) of Directive 2009/138/EC.
The sentence "This template contains an item–by–item list of assets held directly by the group (i.e. not on a look–through basis)…. is the same in the solo and in group template. The objective is to ensure that the look through is not done in S.06.02 but only in S.06.03.
The issue you're raising is different and is not covered by this sentence. The reporting of this UCIT in the S.06.02 will depend on the method of the consolidation.
But please note that in S.06.03 the group should include the look-through of all collective investment undertakings, or investment packaged as funds and similar undertakings, including when they're participations.