Question ID: 1896
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 171, 35
Template: S.06.03
Status: Final
Date of submission: 12 Jun 2019
Question
Art. 171a (2) C(2019) 1900 final "Long-term equity Investments" states that the criteria can be applied on the level of the fund share and not on the level of the underlyings of the fund. This would lead to the calculation of the SCR equity risk on the level of the fund share (Pillar 1).
However, Pillar 3 reporting requirements still require a full look-through reporting for collective investment undertakings in the QRT S.06.03. Our understanding is that long-term equity investments would still be considered to be collective investment undertakings and would have to be reported on a full look-through basis based on DR (EU) 2015/2450 regarding „S.06.03 — Collective Investment Undertakings — Look Through Approach“.
EIOPA answer
First the 06.03 does not require a full look-through, only look-through by class of assets, geographical zone and high level currency.
The look-through reporting is not requested for the purposes of SCR calculation but to assess the prudent person principle, so yes, no exclusions from this template are foreseen at this moment
Any comment on the approach could be considered in the future 2020 review.