Question ID: 131
Regulation Reference: Guidelines on submission of information to NCAs (Preparatory phase)
Article: 35
Template: S.06.02
Status: Final
Date of submission: 27 Jan 2015
Question
In relation to QRT S.32.01.g, I have encountered myself with the following question:
In QRTs S.06.02 and S.08.01 a company has to identify if subordinated debt is a participation or not (I understand subordinated debt corresponds to CIC category 28). Nevertheless, in QRT S.32.01, and in particular in cell M1, EIOPA doesn't mention the subordinated debt as a participation that has to be reported. Can you clarify if subordinated debt has to be identified as a participation for this QRT in general? If yes, cell M1 should include it, correct?
EIOPA answer
In fact there was a mistake in template S.06.02. Subordinated debt cannot be classified as participation. The LOG of this template was amended for the public consultation of the Technical Standard.
However, please note that in the template Participations (not included in preparatory phase) information on whether the undertaking holds subordinated debt of any participation will be required.
Template S.32.01 is correct.