Question ID: 2180
Regulation Reference: (EU) No 2015/2451 - templates and structure of the disclosure of specific information by supervisory authorities
Topic: Disclosure Templates
Article: N/A
Template: S.06.02
Status: Final
Date of submission: 07 Aug 2020
Question
For bank accounts: 1. what is the most appropriate CIC code to use? Do you expect XT71 or XT72? 2. should we report negative bank accounts in S.06.02? If not, where should we report them? In which template should we report negative bank accounts? 3. should we report pending transactions in S.06.02? 4. If the amount is a bank overdraft, is it allowed to report it in S.06.02? And under which CIC code should we report it?
Background of the question
We typically allocate bank accounts in S.06.02 under CIC code XT72. In our case, we encountered an issue regarding a combination of a negative bank account with CIC XT72.
EIOPA answer
For regular bank accounts, based on the submitted question, the CIC classification would be XT72.
The item "Total Solvency II amount" in S.06.02 - List of assets should not be negative for assets with a CIC code equal to '##7#' unless there was an offset in the balance sheet and if both the legal right of offset and demonstrable intention to settle net exist.
If the Solvency II amount is negative it is not an asset but a liability. List of assets need to reflect the assets reported in the balance sheet were no netting should be considered. The only exception is bank overdrafts. As deposits are reported by currency/bank it might happen that this amount is negative if both legal right of offset and demonstrable intention to settle net exist.
Please see also instructions for Cash and cash equivalents in the balance-sheet: “Bank accounts shall not be netted off, thus only positive accounts shall be recognised in this item and bank overdrafts shown within liabilities unless where both legal right of offset and demonstrable intention to settle net exist". See also Q&A 452 and 2076.
Pending transactions should be reported in S.06.02 if it reflects a positive value. Please see Q&A 1904 on the CIC categorisation