Question ID: 2024
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Template: S.08.01
Status: Final
Date of submission: 11 Oct 2019
Question
According to EIOPA logfiles of S.08.01 (C0330 Counterparty Group) en S.08.02 (C0270 Counterparty Group) this field is only applicable to OTC derivatives. As the IRS Swap is going through CCP (Central Clearing House), no information should be required for S.08.01 (C0330 Counterparty Group) and S.08.02 (C0270 Counterparty Group). IRS Swap through CCP will be representing as CIC XTD1 as agree (see EIOPA Q&A no 1855). In the EIOPA validation BV811 and BV824, information is required for the field Counterparty Group, where CIC matches with XT or XL.....Referring to Q&A no 1855, no information is expected for IRS SWAP through CCP. As the CIC XTD1 is correct, should the validation be adjusted for BV811 and BV824?
EIOPA answer
The 2.4.0 update of the log files does no longer refer to the counterparty code only being applicable to OTC derivatives. Therefore, the current validation can remain as it is, but the reference to the OTC derivatives in the error message needs to be amended.