Question ID: 143
Regulation Reference: Guidelines on submission of information to NCAs (Preparatory phase)
Article: 35
Template: S.02.02
Status: Final
Date of submission: 04 Feb 2015
Question
We find problems with regards to interpretation of Guidelines for S.35.01.
Guidelines prescribe to fill this QRT for (re)insurance undertakings under method 1 and method 2, except for the (re)insurance undertakings under method 2 situated in equivalent non-EEA countries. Also, sum of TPs reported in cells D1, G1, J1, M1, P1 for entities under method 1 should match respective numbers for TPs in Group balance sheet QRT (S.02.02, cells L1, L4, L6B, L7, L10).
However, participations in (re)insurance undertakings which are not subsidiaries, if consolidated under method 1, do not contribute to group TPs in the balance sheet (since according to paragraph G.16.d of Technical Specification, adjusted equity method should be used). Therefore, cross template checks for them seem to become broken.
Should we then report participations in (re)insurance undertakings which are not subsidiaries in S.35.01? If yes, for the purpose of S.35.01, should we report "Method of group solvency calculation used" as method 1 or method 2?
EIOPA answer
Non-controlled participation (NCP) are excluded from the scope of template S.35.01.g (old G14) as NCP are assessed through the adjusted equity method and consequently the technical provisions are already included in such assessment.
The aim of the template is to make the link with the consolidated balance sheet and NCP do not contribute to TP in the consolidated balance sheet (NCP are not consolidated line by line).