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European Insurance and Occupational Pensions Authority

1674

Q&A

Question ID: 1674

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

Article: 35

Template: S.20.01

Status: Final

Date of submission: 06 Sep 2018

Question

Could you please clarify which claims should be considered as basis for the analysis in template S.21.01. We think that two interpretations are possible:

1.    In the template S.20.01 only claims are considered which are RBNS claims at a specific date of the current reporting year. Therefore the title of the template S.20.01 “Development of the distribution of the claims incurred” implies that in general (and therefore esp. for S.21.01) by the term “claims incurred” only such claims are meant. In addition in template S.21.01.C0050, C0070, C0090, C0110, C0130, C0150, C0170, C0190, C0210, C0230, C0250, C0270, C0290, C0310, C0330/R0010 to R0210 the instructions suggest that only such closed claims should be considered which ended with payments. Therefore one could argue that only the following claims should be the basis for template S.21.01: All claims which are open at the end of the current reporting year plus all closed claims for which there was a payment during the current reporting year.

2.    On the other hand the instructions for the template S.21.01, considered separately, suggest that all claims, open or closed, should be taken into account, for the latter independent of the year, in which they were closed. The only restriction would consist in the fact that only information for claims with accident/underwriting year N to N-14 has to be reported.

EIOPA answer

EIOPA confirms that in S.21.01 should include all claims, open or closed, independently of the year, in which they are closed. Only information for claims with accident/underwriting year N to N-14 are to be reported.