Question ID: 1687
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Template: S.03.01
Status: Final
Date of submission: 13 Nov 2018
Question
The presentation „Reporting and Disclosure Public Event with stakeholders Input received in the call for input“ (12. April 2018) included the following statement relating to QRT S.03.01:
“Although EIOPA has stated a number of times via the Q&A that only off-balance sheet items are to be reported, pledged collateral cannot be anything other than on-balance sheet – otherwise, there would be nothing to report. This is because an entity can only pledge its own (on-balance sheet) assets as collateral; it cannot pledge someone else’s assets. So far, firms have tended to disregard this apparently illogical guidance, and have reported on-balance sheet assets where these have been pledged as collateral.”
This statement is contrary to the answers EIOPA gave in the Q&A process (e.g. #934, 27. Jan 17 and #1322, 05. Oct 17).
Could EIOPA please advise whether on-balance assets that are pledged as collateral have to be included in the upcoming reporting of Off-balance sheet items QRT S.03.01 or not?
EIOPA answer
The presentation at stake referred to comments from stakeholders received during the call for input. The part identified in the question relates to a stakeholder comment and not to EIOPA's statement.
EIOPA disagreed with the statement as reflected in the referred Q&A. If an asset/liability is presented as on-balance sheet, it shouldn't be presented in the same time as off-balance sheet.