Question ID: 1548
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Status: Final
Date of submission: 27 Jul 2018
Question
The CIC code is considered as a master data and therefore unique for an Asset ID Code. In the previous example related to bank account, if a BIC/ Swift code is used as the Asset ID code and the company hold several accounts in the same bank in the same currency but one is pledged as collateral and another free, this would mean should have different CIC codes (respectively 7.9 and 7.2). This would imply an additionnal criteria to be added to the Asset ID code (Code + currency). Could you please confirm? If not, please advise.
EIOPA answer
We confirm that the asset ID must be unique and kept consistent over time while the CIC must be used to classify assets and undertakings shall take into consideration the most representative risk to which the asset is exposed. In the case described, the assets (deposits) differ from each other, so neither CIC nor asset ID will be the same.
If assets are partially pledged there should be a differentiation in the cell C0100 of Template S.06.02. There should be two reporting lines with the same Asset ID and CIC but a differentiation from the cell C0100.