Question ID: 22
Regulation Reference: Guidelines on submission of information to NCAs (Preparatory phase)
Article: 35
Template: S.06.02
Status: Final
Date of submission: 06 Mar 2014
Question
1) S.06.02 template for group (old AS-D1) indicates in cell A16 that we have to make the distinction between NCP1 and NCP2. Do you agree on the fact that there is no difference between SCR consolidation for a NCP1 and a NCP2 (that is to say: we multiply the SCR of the NCP by the participation percentage and add it to the SCR group)?
2) It is indicated that S.25.01 for group (old SCR-B2A) is applicable when method 1 is used: shall cell A13 contain only SCR from NCP consolidated with method 1 (if insurance undertaking)?
3) On the contrary, in S.33.01 (old G03), if insurance undertaking, do we have to report only NCP in method 2? With all sub-module SCR (Market, underwriting, etc…)?
4) In S.06.02 template for group (old AS-D1), do you agree on the fact that, if cell A16=NCP2, the legal name of the undertaking (A50) and the Issuer Name (A8) refer to the same “entity”?
5) In S.06.02 template for group (old AS-D1), in cell A16 when combination of methods is used, does SM2 and ORUT1 refer to the same type of subsidiary (ie: other related undertaking which are subsidiaries as defined p.53 in EIOPA_13_415_Final_Report_on_CP10) ?
EIOPA answer
1) For the purpose of reporting, there is a distinction between NCP1 and NCP2. However, for the purpose of SCR, the SCR treatment for NCP1 and NCP2 is the same under method 1 and under method 2.
2) In fact S.25.01 is only applicable under the consolidation method or the consolidated part when using the combination method. Therefore cell A13 should reflect the Operational risk capital charge as calculated using method 1 (either alone or in combination with method 2).
3) Your understanding is correct.
For all (controlled and not controlled) participations in EEA insurance or reinsurance undertakings and non-EEA insurance or reinsurance undertakings when Solvency II Directive rules are used and when the method 2 is applied, individual requirements including the individual Solvency Capital Requirement split by different risk categories, individual Minimum Capital Requirement, eligible individual own funds to cover the Solvency Capital Requirement and information on the use of simplifications in the standard model or (partial) internal model should be reported for each entity.
Additionally, for all (controlled and not) participations in non EEA insurance and reinsurance undertakings all local capital requirements, minimum capital requirements and eligible own funds in accordance with local rules, regardless of the method of calculation should be reported for each entity.
4) The cell Issuer Name (A8) should in fact be the same as the name of the undertaking (A50).
5) No. SM2 refers to subsidiaries under method 2 which include insurance and reinsurance subsidiaries (cf. Annex I para 7 (b) 3rd and 4th bullets) while ORUT1 refers to subsidiaries under method 1 other than insurance and reinsurance undertakings, insurance holding companies, ancillary services undertakings and special purpose vehicles (cf. Annex I para 7 (a) 4th bullet).