Question ID: 1554
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Template: S.12.01
Status: Final
Date of submission: 09 Aug 2018
Question
For our UL business, BEL is account value plus the discounted value of cfs outside the UL account. In addition, RM is calcualted. So for the part of BEL that is taken directedly from the account value, should it be reported under BEL or TP calculated as a whole in S.12.01.01?
In S.13.01.01, the cfs for this UL business should be gross or net of the account value?
In S.29.03.01 and S.29.04.01, whether the technical flows for UL business is gross or net of account value?
EIOPA answer
The TP are either calculated as TP as a whole or as BE + RM. If the undertaking is able to unbundle the contract such that at least a part of the liability cash-flows can be replicated in amount and timing, then it is possible to have that part of the TP calculated as 'TP as a whole' and the remaining part as 'BE+RM'
The templates should reflect the approach taken, i.e. in template S.13.01 only the amount of best estimate is to be reported, in S.29.03 the main table (R0010 to R0290) reflects only amounts related to best estimate, i.e. it does not include the risk margin, technical provisions calculated as a whole nor the transitional measure on technical provisions. However, in R0360 the amounts refers to total technical provisions, so including best estimate, risk margin, technical provisions calculated as a whole and the transitional measure on technical provisions, in template S.29.04 the variation of best estimate and of TP calculated as a whole are requested in different rows.
That means, when reporting of BE is required, only the amounts of BE that relate to the part of TP calculated as BE + RM should be reported.
For the unit-linked business, in S.29.03 the best estimate related to index-linked and unit-linked business should also be included in R0010 to R0290, preferably in R0010‑R0140, i.e. by underwriting year. In S.29.03.R0300 the net impact of the amount of the assets held by index-linked and unit-linked business and of technical provisions – index-linked and unit-linked (calculated as best estimate and risk margin or calculated as a whole), including the technical flows, should be reported for information and in S.29.04. all amounts to be reported in R0010 to R0050 and from R0080 to R0120 should include amounts related to index-linked and unit-linked business. In R0060 and R0130 the net impact on EoAoL of the amount of the assets held by index-linked and unit-linked business and of technical provisions – index-linked and unit-linked (calculated as best estimate and risk margin or calculate as a whole) should be reported split by periods for information.