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European Insurance and Occupational Pensions Authority

2359

Q&A

Question ID: 2359

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

Topic: Reporting Templates

Article: Article 35 of SII Directive

Template: S.02.01

Status: Final

Date of submission: 24 Nov 2021

Question

We require further clarification to the answer provided for EIOPA Q&A 2215. We currently report outstanding trade settlement receivables/payables, that are the subject of this Q&A, to the Irish regulator (the CBI) under Other Assets (R0420)/Other Liabilities (R0880) in Irish solo entity returns and to the UK regulator (the PRA) under Receivables, Trade not Insurance (R0380)/ Payables, Trade not insurance (R0840) for UK solo and UK Group returns. The proposed treatment of these receivable balances given the response issued to Q&A 2215, where it has been suggested these items should be reported as cash and cash equivalents (R0410), appears to contradict the presentation of the same balances in statutory reporting. It also contradicts the answer provided to EIOPA Q&A 870, as an example, where it was concluded that if it is not possible to freely dispose over the cash that it was more appropriate to record the balance as a receivable amount in R0380. Further, the S.06.02 guidance stipulates to only bring in assets that fit into the Annex V: Definitions of the CIC Table. This table defines CIC 7s as ‘Money in the physical form, bank deposits and other money deposits’. These receivable amounts do not appear to meet this criteria. Can you please confirm it is appropriate to continue recording outstanding trade settlement amounts where cash is due but has not yet been received as receivable amounts either in R0380 or R0420 and the equivalent treatment for payables in R0880 or R0840.

Background of the question

EIOPA Q&A 870, 1904, 2215

EIOPA answer

Please note that Q&A 2215 has been revised.