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European Insurance and Occupational Pensions Authority

1826

Q&A

Question ID: 1826

Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities

Article: 35

Status: Final

Date of submission: 11 Apr 2019

Question

We have a question on how the 90% look-through by country and currency rules interact with underlying asset category.

We can see that for example, in isolation, sum(S0603 c0060) where c0040 = 'AA' should not  be > 10% of total s0603 c0060 (taking into account c0030 = 8 or 9)

However, what rule applies to C0030 being 4? This is also applied in isolation? or in combination a rule applied eg that >90% of the total S0603 c0060 must have c0030 <> 4 AND c0040 <> AA AND c0050 <> 3 (excluding s0603 rows where c0030 is 8 or 9)

EIOPA answer

As a background information:◦The template S.06.03 should include information corresponding to 100% of the value invested in collective investment undertakings;
◦The look-through should be applied considering the amount invested, starting from the major to the lowest single fund and the approach should be kept consistent over time.

Then (after having ranked the funds from the largest to the smallest as discussed above) the look-through has to be applied until both the following conditions are fulfilled:

a- For the identification of countries the look–through should be implemented in order to identify the exposures of 90% of the total value of the funds minus the amounts related to CIC 8 and 9 (i.e. deduct 8 and 9 from the denominator);

b- For the identification of currencies the look–through should be implemented in order to identify the exposures of 90% of the total value of the funds.        

Basically, the look-through can stop when both conditions a) and b) are  fulfilled. Also, note that undertakings should have a reasonable confidence that the 10% not identified by country is diversified across geographical areas, for example that not more than 5% is in one single country.

In the light of the explanation above the following conditions should be checked for C0030=4 one by one and should all be fulfilled:
◦>90% of the total S0603 c0060 must have c0030 <> 4  AND
◦>90% of the total S0603 c0060 (minus 8 and 9) must have c0040 <> AA AND
◦>90% of the total S0603 c0060 c0050 <> 3