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European Insurance and Occupational Pensions Authority

2203

Q&A

Question ID: 2203

Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities

Topic: Risk concentration

Article: Article 335(1)f of the Delegated Regulation 2015/35

Template: S.37.01

Status: Final

Date of submission: 01 Oct 2020

Question

I understand that the scope of S.37.01 is consistent with the population of S.32.01 for those entities subject to group supervision. Is the intention of S.37.01 to capture collective investment undertakings and their underlying asset exposures as well as operational entities of the group in the context of counterparty default risk, given that the insurance entities of the group are exposed to the funds ability to settle its published redemption value regardless of whether the group owns >20% or not. If the intention is definitely to capture collective investments within the scope of the group for this purpose, is it to be understood that the exposure reported is intended to be for the collective investment undertaking as a whole simply because it appears on S.32.01, regardless of the group's ownership? Alternatively, is the intention to capture the group's share of the fund's exposure. For example, if an insurance undertaking has a 500m reporting threshold and has a 450m bond holding directly on its balance sheet and holds 25% of a fund which itself has a 100m holding with the same ultimate parent, does the group exposure breach the threshold as being 450m + 100m or does it not because it's limited to 450m + (100m * 25%) = 475m. If the former, this would appear to give an inflated view of the group's exposure but is the answer logically reached if each entity reported on S.32.01 must be considered as a whole.

EIOPA answer

The data on related Collective Investment Undertakings are to be included in the consolidated data on the basis of the proportional share held  according to Article 335(1)f of the Delegated Regulation 2015/35, if method 1 applies.

Therefore, the exposures on CIUs should be reported in the template S.37.01 taking into account the proportional share held (25%, i.e. in the example).