Question ID: 1349
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 3, 35
Template: S.19.01
Status: Final
Date of submission: 15 Sep 2017
Question
We would like clarification around the conversion of original currencies to reporting currency in order to create the "Total" triangles required in S.19.01.
Our understanding from Article 3 - Currency of the Regulation No 2015/2450 is that each diagonal would be converted at their specific reporting date so that the historic data in the triangles under "Total" would not change.
However comment 366 under the Q&A outlined above (https://eiopa.europa.eu/Pages/Consultations/Public-consultation-on-the-…) states that the entire triangle should be converted at the latest reporting date i.e. the historical data under "Total" triangles will change at each reporting period.
We would appreciate clarification on this as a number of firms have interpreted the Regulations, while others are following the reply under the Q&A.
EIOPA answer
EIOPA confirms the answer provided in Q&A, i.e. the entire triangle should be converted at the latest reporting date. This would mean that the historical data under "Total" triangles will change at each reporting period but makes the claims amount more consistent for an actuarial analysis of the claims.
The application of Article 3 of the ITS is not straightforward as this template relates to historical data and not to 'income or expense' from the reference year of the reporting. This could be further clarified in a future revision.