Question ID: 1414
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Template: S.11.01
Status: Final
Date of submission: 29 Nov 2017
Question
1. Question:
On several places in the instructions to S.11.01 are mentioned that "This item is not applicable for CIC category 8 — Mortgages and Loans (for mortgages and loans to natural persons, as those assets are not required to be individualised)".
Did you mean: "This item is not applicable where the collateral relates to CIC category 8 — "Mortgages" and "Loans" on the balance sheet (for mortgages and loans to natural persons, as those assets are not required to be individualised)"
For example: loans on policies has XT86 but the collateral has in my opinion XT09 since the Policy doesn´t fit anythere else in CIC-Matrix. Following the current instructions there would have to be data needed for example in C0080 Country of custody because XT09 is not exempted.
(Question 1.1: or do you want us to provide XT86 in C0250 CIC for the collaterals on "loans on policies"?)
2. Question:
What is the Collateral for XT84: the entitlement by a land charge/Grundschuld or the land/property?
Since the entitlement is limited to an amount defined in the contract it would be easy to provide that in C0120 Total amount.
The present value isn´t that easy to provide in case you wish land/property as the collateral.
EIOPA answer
In fact, the intention is to read the instructions as for the assets of the Balance-Sheet being covered as also the collateral of those assets should be reported in one single row in S.11.01. See also Q&A 1384.
Regarding collaterals of assets classified as 'XT84', i.e. when assets for which the colateral is held is a CIC84, the collateral should be the land/property. C0060 to C0130 and C0150 to C0280 should relate to the land/property.