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European Insurance and Occupational Pensions Authority

1465

Q&A

Question ID: 1465

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

Article: 35

Template: S.17.01

Status: Final

Date of submission: 20 Feb 2018

Question

I am contacting you regarding a duplicate fact between QRTs S.17.01.01 (cell C0180/R0480) and S.22.06.01 (cell C0030/R0020/Z0010).
While we do expect both cells to share the same values, general comments for QRT S.22.06 on the ITS logs are stating the following:
Information shall be reported in relation to material obligations in countries and currencies for which a currency volatility adjustment, and a country increase if applicable, is applied until 90% of the total best estimate subject to volatility adjustment is reported.

A similar requirement is not present on S.17.01 instructions, however since BE is reported by line of business on this QRT we assume the BE subject to volatility adjustment must be reported up until 100% here. As a result, there is a high chance of discrepancy between two QRTs on the same fact. A technical workaround consists of reporting 100% of BE on S.22.06, which can be done either by covering data up to 100% for all countries and currencies, or reporting the missing 10% for a single country.

Do you agree with our analysis? Is there a specific method to report data, that is not covered by the instructions?

EIOPA answer

The Data Points are correct and reflect the intention of the template. In the template S.22.06 the amount corresponding to 100% of the amount should be reported in R0020/C0030 and then at least 90% of that amount should be split by currency and country.

The instructions of this cell say: “Total value, for all currencies and all countries, of the best estimate of the insurance and reinsurance obligations subject to volatility adjustment .” However, we do agree that the Instructions could be made more clear. This will be considered in the next revision of the Instructions.