Question ID: 1714
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 335, 35
Template: S.02.01
Status: Final
Date of submission: 12 Nov 2018
Question
In group balance sheet S.02.01 OFS have to be included with their sectoral own funds (article 335 of delegated regulation 2015/35).
There are several XBRL-validations checking if the reported Solvency II values (C0010) in QRT S.02.01 and Total Solvency II amounts (C0170) in S.06.02 are consistent.
Therefore we are wondering if you also expect the sectoral own funds to be reported as „Total Solvency II amount“ of an OFS in group S.06.02?
If so, there seems to be a contradiction to annex 3 of ITS 2015/2450 which defines "Total Solvency II amount" as the multiplication of “Par amount” by “Unit percentage of par amount Solvency II price” plus “Accrued interest” or otherwise the multiplication of “Quantity” by “Unit Solvency II price”.
EIOPA answer
In fact there are two different approaches leading to the same prudential result followed by different NCAs:
Approach 1: Those who value the related undertaking from other financial sectors as the proportional share of the own funds according to applicable sectoral rules consider that Article 335 of Delegated Regulation should be used for the purpose of both determining the consolidated data and valuing related undertakings in the group balance sheet;
Approach 2: Those who value the related undertaking from other financial sectors in accordance with Article 13 of the Delegated Regulation considering that the general valuation principles provided in Articles 224 of the Solvency II Directive and 13 of the Delegated Regulation still apply for the purpose of valuing such related undertakings in the group balance sheet.
As this lead to the same contribution to group own funds both approaches are accepted and you should consult your NCA to know which approach to follow.
In case it is approach 1 the same value should be reported in both 02.01 and 06.02. and in 06.02 please identify 4 - adjusted equity methods (applicable for the valuation of participations) in C0150 and provide only the total SII, please leave C0130/C0140 and 370/380 empty.