Question ID: 1384
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: 21 Nov 2017
Question
Is our assumption true that real estate which serves as security for mortgages and loans (CIC 8) to natural persons (e.g. mortgage loans to employees) should be reported as an off-balance-sheet-item in S.11.01 and in S.03.01 because the reporting entity has individual recourse rights to the property?
EIOPA answer
Template S.11.01 includes the off-balance sheet assets held as collateral for covering balance sheet assets held directly by the undertaking and this amounts should in fact be also reported in S.03.01 in C0020/R0100 to R0130.
Regarding the real estate held as collateral of the mortgages related to individuals, these should reported in S.11.01 but in one single line, reflecting the approach taken for the item being covered in template S.06.02.