Question ID: 1303
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Template: S.06.02
Status: Final
Date of submission: 16 Aug 2017
Question
Question 1:
In the Underlying asset category (C0030) we find in the closing list "L-Liabilities". Is this referring to liability in cash? In the look through information we have got a negative value for CIC 7.
Question 2:
According to the EIOPA Logfile in the general comment "Items shall be reported with positive values unless otherwise stated in the respective instructions". As in the "Total Amount" only mention:
- Liabilties should be reported positive
- derivatives can be positive or negative
I suppose al other asset should be reported only positive. For example: if CIC 7 has negative value, we should be reported this as positive value. Is this correct?
That means, you could not match the total underlying value of the fund from the "Total Amount" in the S.06.03 with the value of the fund in the "Total Solvency II amount" of the S.06.02 report. No validation could be made between the total value of the underlying of the fund (S.06.03) and Total Solvency II amount in the S.06.02. Do you agree with this conclusion?
Question 3
Is it not necessary to recognize negative value of the CIC 7?
EIOPA answer
The closing list "L-Liabilities" in C0030 refers to all liabilities except derivatives, including liabilities resulting from a negative amount in cash. Any asset, cash or other, with negative amount is considered a liability and should be reported as "L-Liability" (no netting).
We confirm that your understanding for reporting only positive values in C0030 is correct (except for derivatives). As such if CIC 7 has negative value, it should be reported as a positive value but in L-Liabilities (not as "7 - Cash and deposits").
The match is possible as we should be able to sum all asset categories except Liabilities, then deduct the amount reported as Liabilities.