Question ID: 1723
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Template: S.29.01
Status: Final
Date of submission: 22 Jan 2019
Question
I have a question on this explanatory note. The paragraph 1.15 page 4 don't match withe the paragraph 1.33 page 11.
Since in paragraph 4 the own share are excluded with S.29.01.R0190 equal to sum of S.29.02.R0010, S.29.02.R0030, S.29.02.R0040 minus S.29.02.R0050 while in the other paragraph it become : S.29.02.R0060 equal to sum of S.29.02.R0010, S.29.02.R0020 S.29.02.R0030, S.29.02.R0040 minus S.29.02.R0050
But due to the DPM S.29.02.R0060 and S.29.01.R0190 refer to the same information (DataPoint Signature : MET(s2md_met:mi305)s2c_dim:DI(s2c_DI:x5)s2c_dim:VG(s2c_AM:x80) ), so only one of these two formula can be used here. The questoin is which one? I think it should be the first one since own funds aren't investment, but I would appreciate your input on this question.
EIOPA answer
The “EIOPA-17-403-Explanatory notes on VA templates” for the items R0190C0030 in S.29.01.01 and R0060C0010 in S.29.02.01 and related formulas are correct.
However, as described in the question the EIOPA XBRL taxonomy version 2.3.0 is currently having only one placeholder for both items.
Therefore, users of the EIOPA XBRL Taxonomy are requested to overcome the issue as further described in the Taxonomy list of known issues available in the EIOPA website. i.e taxonomy users could be requested to report both elements including the own founds till a fixed taxonomy is available, noting also that in the meantime the correct value to be reported in cell R0190C0030 in S.29.01.01 template could be estimated by subtracting value reported in cell R0020C0010 from value reported in cell R0060C0010 of S.29.02.01 template.