Question ID: 179
Regulation Reference: Guidelines on submission of information to NCAs (Preparatory phase)
Article: 35
Template: S.25.01
Status: Final
Date of submission: 10 Aug 2015
Question
The log states that cell A11 should be equal to the following: A11=max (min(B10-A10;A11B);0).
A11B does not exist on this template (although it does exist on both S.25.01.b and S.25.01.g).
A non-existent A11B means the following:
A11 = max (min(B10-A10;A11B);0)
= max (min(B10-A10);0)
= max (B10-A10;0)
= B10-A10 since B10-A10 >0
In this case, the loss–absorbing capacity of technical provisions is not limited by the value of net future discretionary benefits, which is clearly not the intention of the above formula so this option cannot be correct.
A zero A11B means the following:
A11 = max (min(B10-A10;A11B);0)
= max (min(B10-A10;0);0) since B10-A10 >0
= max (0;0)
= 0
In this case, the loss–absorbing capacity of technical provisions is zero, which is clearly inaccurate so this option is also not correct.
Our intended approach is, therefore, as follows:
• calculate a ‘notional’ A11B for this template
• input this value of A11B into the formula above to calculate A11 (despite the fact that this value of A11B will not be reported on any template).
Can you confirm our approach is suitable?
EIOPA answer
EIOPA confirms the approach proposed.
Please note that template SR.25.01 (that corresponds to old S.25.01.l) published in the Final Report on public consultation No. 14/052 on the implementing technical standards on the templates for the submission of information to the supervisory authorities already includes the row corresponding to “Net future discretionary benefits”