Question ID: 1213
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Template: S.11.01
Status: Final
Date of submission: 21 Jun 2017
Question
Log for S.11.01 – Assets held as collateral, fourth paragraph, states that “If there is a pool of collaterals or a collateral arrangement comprising multiple assets, as many rows as the assets in the pool or arrangement shall be reported.” Should collateral referring to one covered bond be reported at one row?
See also QA 872, there is a good explanation of collateral and covered bonds.
EIOPA answer
Collateral in case of "Covered bonds" is not to be reported in S.11.01. Covered bonds are "traded assets" where generally the collateral is a pool of assets, to which the bond holder does not have individual rights (ie, in case of shortfalls, asset A belongs to bondholder A).
Collaterals, to be included in the reporting are the ones "held". Collaterals are considered "held" when the undertaking has the "right of direct access to the collateral", so the collateral has been committed to the entity and is individually identifiable. For further information see also Q&A 988.