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European Insurance and Occupational Pensions Authority

130

Q&A

Question ID: 130

Regulation Reference: Guidelines on submission of information to NCAs (Preparatory phase)

Article: 35

Template: S.02.01

Status: Final

Date of submission: 10 Sep 2014

Question

The General Comment in the July 2012 LOG for Assets-D1 (S.06.02) states, "CIC 8X (Mortgages and loans): for mortgages & loans to individuals, including loans on policies, there must be only 2 lines, one line regarding loans to senior management board and another regarding loans to other individuals, without distinction between individuals". These correspond to cell A14B in S.02.01.

The LOG for S.02.01 states that "Receivables (trade, not insurance)" (cell A23) "includes amounts owed by employees...".

It is therefore unclear exactly where different employee loans are to be placed in the SII balance sheet. Our assumption is the following:
- loans to senior management: loans/mortgages to individuals (A14B)
- other staff loans: receivables (A23)

Please confirm our assumption is correct. 

EIOPA answer

Cell A14A should include all loan on policies, regardless if the policyholders are also employees of the undertaking or members of the AMSB.
Cell A14B (Loans and mortgages to individuals) should reflect the amount of loans other than loans on policies. 

Cell A23 should include other amounts owed by employees but not related to loans (any value due for any other reason, e.g. training reimbursements initially paid by undertaking)