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European Insurance and Occupational Pensions Authority

1767

Q&A

Question ID: 1767

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: 26 Apr 2019

Question

Regarding the cell C0010/R0030 'Valuation movements on financial liabilities and subordinated liabilities' on template S.29.02, it appears to include all movements on subordinated liabilities. This cell is part of the 'Variations due to investments and financial liabilities' as reported in C0030/R0190 on S.29.01, which means that, by extension, part of the subordinated liabilities reported on S.29.02 may end up included in the 'Excess of assets over liabilities' in cell C0030/R0130.

However, EoAoL serves a basis for the calculation of the 'Variation of Reconciliation Reserve' on C0030/R0180. Following the reasoning, part of the subordinated liabilities may still be included on C0030/R0180, meaning these should also be included in cell C0030/R0080 of the same template S.29.01. Since C0030/R0090 is dedicated to 'Subordinated liabilities' as well, do you think there is a chance of double counting variation movements for subordinated liabilities on table 1 of template S.29.01 (a small fraction of these movements in C0030/R0080, and the bulk of it in C0030/R0090)?

EIOPA answer

In "EIOPA Explanatory notes on reporting templates - Variation Analysis templates" 1.16 the cell C0030/R0190 on template S.29.01 corresponds to the sum of S.29.02.R0010, S.29.02.R0030, S.29.02.R0040 minus S.29.02.R0050 and the subordinated liabilities are taken into account. At the same time, in SolvencyII Validations the cell C0030/R0190 on template S.29.01 is not equalt to cell C0010/R0060 on template S.29.02, which is Variation in Excess of Assets over Liabilities explained by Investments and financial liabilities management.