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European Insurance and Occupational Pensions Authority
 

1421

Q&A

Question ID: 1421

Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities

Article: 35

Template: S.29.03

Status: Final

Date of submission: 03 Apr 2018

Question

We have a question concerning the variation analysis. We are not sure in which step to report the variation of the best estimate due to projection of incorrect future cashflows, because of an incorrect projection of cashflows of the first year.
For example:
In S.29.03 step "Variation of Best Estimate due to experience and other
sources - risks accepted/covered prior to period (R0080/R0230)" we have to
report only the first year. (According to the legal text 2015/2450: The variation of Best Estimate captured here shall strictly relate to the strict
realisation of cash flows when compared to the cash flows that were projected.)

Assume a projected cashflow of 1 million due to surrender, but the actual cashflow was 2 million. Then this will affect all future cashflows as well, as for example cashflows that are projected can no longer occur because these contracts lapsed. Consequently, not only the cashflow in the first year but all other cashflows have to be adapted to obtain the closing best estimate.

As a consequence the position "other changes not elsewhere shown (R0110/R0260)" would include a lot of positions making the analysis of variance harder to interpret.

EIOPA answer

Regarding this example the following should be reported:
-    In R0070 adjustment for the projected 1 million;
-    In R0080 adjustment for the future CF of the new situation after 2 million surrenders;
-    In R0320 surrender value.The answer will also be uploaded on our website according to the procedure.