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European Insurance and Occupational Pensions Authority

1508

Q&A

Question ID: 1508

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

Article: 35

Template: S.22.05

Status: Final

Date of submission: 15 May 2018

Question

We note that the instructions for S.22.05 have been updated as expected from discussions with the XBRL team but we don't believe the updated make sense and will not work with the updated validation BV70 if followed to the letter.

R0070 instructions state it should be the TMTP after any limitation has been applied. If no limitation is applied the same amount as in cell R0060 should be entered but R0060 is a %, the proportion of the difference applied. Should the instruction for no limitation read 'if no limitation applied then the same as R0020 + R0030 + R0040 - R0050 * R0060? The description of R0070 does not match up with what it is supposed to contain.

The form would make more sense if R0070 was the limitation, if any to be applied, or zero if not. It would then contain all the information required to work out the TMTP adjustment and would flow in a readable way.

EIOPA answer

BV70 reflects an amendment that was not included in the 2017 final Commission ITS. The amendment will be published this year and the validation should be applied to the next release of the XBRL package.