Question ID: 1943
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Status: Final
Date of submission: 12 Jul 2019
Question
We identified some Validation rules that seem to to contradict each other. In the following please find the sets of contradictory validations:
BV786 vs. BV955: The definition for BV786 regarding CIC ##09 is contradictory to BV955.
BV776 vs. BV981: The definition for BV981 regarding CIC ##09 is contradictory to BV776.
BV792 vs. BV956: The definition for BV792 regarding CIC ##09 is contradictory to BV956.
BV794 vs. BV985: The definition for BV985 regarding CIC ##8# and CIC ##09 is contradictory to BV794.
BV777 vs. BV982: The definition for BV982 regarding CIC ##8# and CIC ##09 is contradictory to BV777.
Please advise how the valdiation rules should be fulfilled.
EIOPA answer
These validations are not contradictory but complementary.
BV786 indicates that "Holdings in related undertakings, including participations" in S.06.02 should be empty for assets with CIC different from '##3#' or '##4#' or '##09' .
BV955 indicates that "Holdings in related undertakings, including participations" in S.06.02 - List of assets should be reported for assets with CIC '##3# 'or '##4#'.
As a result, for CIC '##09' the field can be reported or left empty depending on the type of 'other investments'.
The same logic is to be applied for the validations BV776 vs. BV981 and BV792 vs. BV956.
Validations BV777 and BV794 had already been deactivated and will be removed in 2.4.0 thereby avoiding any contradiction.