We do have question regarding to different QRT (S.06.02, S.06.03 and S.11.01)

Query 1) concerning S.06.02 (List of Assets):
The following applies to unit-linked life insurance policies: For unit linked life insurance policies a so called Dispositionsstock is reported in S.06.02 (List of Assets) with CIC 4 (fund). The “Dispositionsstock” can be reported with a negative value, because of the following reason:
The incoming premiums at the beginning of the current month for unit-linked life insurances are ordered on an estimation based on the previous month. Estimation mistakes will be eliminated with a second order for unit-linked life insurances in the first or second calendar week of the current month. Indeed the target and actual inventory of unit-linked life insurances should be zero, but the monthly closing is a few weeks later. Between the mentioned periods incoming cancellations will lead to a positive so called “Dispositionsstock”, new business lead to a negative “Dispositionsstock”.
In this case, the negative value is not accounted as a liability. The total sum of the funds for policyholders in the SII-balance-sheet is positive. The negative values do not turn in a liability position.
Therefore we kindly ask you to clarify the specific treatment for those assets. In our opinion other insurance companies have the same problem.

Query 2) concerning S.06.02 (List of Assets):
In another context the SII-Value and the Acquisition Value can also be negative without being a liability: If an insurance company invests in a newly launched private equity fund, but the feeder fund has not yet invested in various projects and initial-financing-dues have already been incurred (for example due diligence costs), the private equity fund has a negative market value. The negative Market Value is not accounted as a liability but as an asset, because valuation is expected to turn positive during the investment period. In this context, a negative SII Value is shown in the Asset QRT S.06.02 on the basis of a negative Market Value. For the same reasons, the Acquisition Value also can be negative.
Would you also clarify the specific treatment for this transaction too?

Query 3) relating to the queries above (I and II):
We kindly ask you to clarify how to handle the negative Values in QRT S.06.03. As we mentioned the negative Value is not a liability. Therefore, in our opinion it seems to be incorrect to report the negative SII Amount with category L-Liabilities in S.06.03.

Query 4) relating to QRT S.11.01 (Assets held as collateral):
We kindly ask you to clarify if a Cash Collateral position, which is shown in the IFRS-balance sheet and therefore reported in S.06.02 (with CIC 79) should also be reported in QRT S.11.01. The economic ownership belongs to the counterpart that is pledging the collateral, although it is accounted by the security holder. We are wondering how to handle such a position at the year-end reporting.