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European Insurance and Occupational Pensions Authority

190

Q&A

Question ID: 190

Regulation Reference: Guidelines on submission of information to NCAs (Preparatory phase)

Article: 35

Template: S.25.01

Status: Final

Date of submission: 29 Oct 2015

Question

In Guideline 15 "Individual quantitative annual information - Ring Fenced Funds" of the Document “Guidelines on the Submission of Information for the National Competent Authorities” (EIOPA-CP-13/010), EIOPA states the following:
“In addition to the information regarding the Solvency Capital Requirement at entity level, the information referred to in paragraph j) of Guideline 13 should be submitted, separately, regarding the Ring Fenced Fund with the most material notional Solvency Capital Requirement and regarding the remaining part of the business of the undertaking using the references S.25.01.l.” (par. 1.55);
•         “The information referred to in paragraphs m) to s) of Guideline 13 (QRTs related to the SCR calculation at module level) should be submitted, separately, regarding the Ring Fenced Fund with the most material notional Solvency Capital Requirement and regarding the remaining part of the business of the undertaking using the references S.26.01.l to S.26.06.l and S.27.01.l.“ (par. 1.56).

While it is clear that it is required to report S.25.01.l QRTs for the RFFs and for the Remaining part “in addition” to S.25.01.b QRT, it is not explicitly stated if undertakings with RFFs have to:
a) submit only the QRTs from S.26.01.l to S.26.06.l and S.27.01.l for the Remaining Part and for the most material RFF only (excluding the submission of all SCR.26.xx.b QRTs and SCR.27.01.b)
or
b) submit the QRTs referred to in point a) in addition to the QRTs from S.26.01.b to S.26.06.b and S.27.01.b.

For undertakings with RFFs, is the submission of S.26.xx.l and S.27.01.l QRTs for the RFFs and the remaining part exhaustive or do undertakings also have to provide all the S.26.xx.b and S.27.01.b QRTs?

EIOPA answer

The text of Guideline 15 (and article 14 of the ITS as 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) is correct. For undertakings with RFF/MAP only the templates S.25 have to be submitted at entity level in addition to the information at RFF/MAP/remaining part level. The templates S.26s and S.27 only have to be submitted at RFF/MAP/remaining part.