Question ID: 1323
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Template: S.03.01
Status: Final
Date of submission: 01 Sep 2017
Question
- Is it correct to interpret the instructions in the LOG file for S.03.01 for groups and EIOPAs answer to Question #1072 (07.03.2017) as follows:
Guarantees where both, the guarantor and the guarantee are group entities, have not to be reported in S.03.01 for groups. Guarantees where only the guarantor or the guarantee is a group entity and the business partner is an external company, have to be reported in S.03.01 as a guarantee, even if that is a kind of double counting as the underlying business (e.g. a loan liability to the external company) is already recognized in the group balance sheet?
- It is explicitly mentioned to not report any guarantees and contingent liabilities within the scope of the group. It is not explicitly mentioned how to proceed related to the collaterals.
Which collaterals does EIOPA expect to be reported in S.03.01 – only collaterals received from / pledged to external companies or internal collaterals where both the provider and the receiver of the collateral are group entities?
EIOPA answer
In S.03.01 are to be reported only limited guarantees. The guarantees listed in this template are not reported in S.03.02 and S.03.03.
We confirm your understanding that internal guarantees within the scope of group supervision are not reported in this template. The same applies for collaterals, e.g. only collaterals received from / pledged to external companies should be reported.