Question ID: 1849
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Template: S.12.01
Status: Final
Date of submission: 12 Jul 2019
Question
Q&A #1732 states that S.12.01 C0150/R0230 = C0150/R0240+C0150/R0250.
We believe this cannot be correct and does not conform with the general structure of the template.
R0230 is for reporting LoBs where "Future guaranteed and discretionary benefits" are combined - R0240 and R0250 are for reporting LoBs where "Future guaranteed benefits" and "Future discretionary benefits" are separated.
Nowhere is R0230 considered to be the total of the two rows below because they never coincide for any LoB.
Therefore C0150/R0230 must be the total of all preceding cells on R0230 not the sum of the cells below - otherwise the values in cells C0030/R0230, C0060/R0230 and C0090/R0230 will not be included in the total column at all.
EIOPA answer
EIOPA reviewed Q&A 1732 to reflect that C0150/R0230 is not expected to be the sum of C0150/R0240+C0150/R0250 as for some LoBs, like UL or other life insurance, there is no split between guaranteed or discretionary benefits. In fact, C150/R230 = C0100/R0240 + C0100/R0250+C0020/R0240 + C0020/R0250 + C0030/R0230 + C0060/R0230 + C0090/R0230.