I see the reply on Nov. We referred to Explanatory Notes on Variation Analysis Template before and could not get the reasonableness of the overall treatment on UL line of business in S.29s. Please allow us to be more specific with the issue.
First, all the case examples in the Explanation paper are for NL business. We don't see a single one capturing UL line of business with an overall picture: S.29.01.01 R0250, S.29.03 R0300/C0090, and S.29.04 R0070/C0010.

Second, to follow "In R0360/C0120-C0130 the BE, RM and TP as whole are considered but the amount is then ‘neutralised’ by the deduction of the amount reported in R0300/C0090 reflecting the variation in the balance-sheet of the Investment held by unit-linked and index-linked business." on page 18 of Explanatory notes, we think S.29.03 R0300/C0090 should be: -deltaBEL+delta UL+cfs                                                                                                                  

However, to follow "- the variation in BE... and variation of TP calculated as a whole (between end of previous year and the reporting year);

- minus the variation in unit-linked (C0090 / R0300);
- plus total amount of net technical flows, i.e.: inflows minus outflows (C0100/R0340 for Life and C0110/R0340 for Non-Life)." on page 14, section 1.35 of Explanatory notes, the signs of delta UL and technical flows should be opposite, which is contradictory from the formula above: -deltaBEL+delta UL+cfs

Third, if S.29.01 R0250 already captures asset and liabilities in UL fund and which is close to each other. And in S.29.03 R0300/C0090: -deltaBEL+delta UL+cfs, where we see first two items might cancel on a large level each other. Then looking at the overall picture by adding S.29.01 R0250, R0200, for UL line of business, by large we will always get:UL asset-UL liability+cfs. We could not interpret the meaning of this and purpose of having that.

Fourth, in S.29.01, whether UL asset and UL liability as a total need to be captured, or the changes in these two items need to be captured?
So a) Please provide specific formulas on S.29s with an UL example in places S.29.01.01 R0250, S.29.03 R0300/C0090, and S.29.04 R0070/C0010, and explain the reasonableness of what in the end S.29s could capture. b) CFs for UL are gross premiums, gross claims, expenses, or just UL fees, expenses, and claims exceeding UL fund? c) If S.29.01 R0250 could already capture the own fund movement due to UL LOB, then why should be bother providing more data items relating to UL LOB in S.29s?