Question ID: 1875
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Template: S.03.01
Status: Final
Date of submission: 12 Apr 2019
Question
In the consulation of amendments of the QRTs in spring 2018 regarding template S.03.01 after the six paragraph in the general comments the following sentence is inserted:
“Internal guarantees within the scope of group supervision are not reported in this template.”
However, the cells R0020 and R0040 in that template still ask for information regarding group internal guarantees ("Of which, guarantees, including letter of credit provided to other undertakings of the same group"). This seems to contradict the explanation which was added as described above. Could you please clarify?
EIOPA answer
EIOPA confirms that the Amendment to the Implementing Technical Standard on Reporting (2018) introduces amendments to S.03.01 in Annex III e.g. group templates. As a result of the amendments the instructions of R0010 and R0030 have been amended. The instructions of cells R0020 and R0040 in the solo template S.03.01 (Annex II) haven't been changed as the general comments section of the solo templates hasn't been amended.