Question ID: 2649
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Tema: Validations
Article: N/A
Template: S.06.02
Status: Revised
Date of submission: 26 May 2023
Question
Regards the updates within 2.8 taxonomy and the associated LOG guidance (in the draft business package supporting SII taxonomy 2.8.0), there is an apparent contradiction between the new guidance and the validations. The final part of the LOG guidance for this cell (from solo instructions) is: “This item is not applicable for CIC category 8 — Mortgages and Loans, CIC 71, CIC 75, CIC 09 and for CIC category 9 — Property and to any other asset that, due to their nature, are not held in custody. For assets where there is no custodian or when this item is not applicable, “No custodian” shall be reported.” The final sentence seems to indicate that in no circumstance should C0120 be left empty i.e. if no other entry is applicable to the item then “No custodian” should be given as the value. But validation BV1213 states that for certain CIC C0120 should be empty: matches({t: S.06.02.04.02, c: C0290, z: Z0001, seq: False, id: v2, f: solvency, fv: solvency2}, "^..((71)|(75)|(8.)|(9.))$") isNull({t: S.06.02.04.01, c: C0120, z: Z0001}) We appreciate BV1213 is a warning, but we think clarity would be helpful regards the updated guidance.
EIOPA answer
Revised answer on 01/02/2024: BV1213 has been deactivated (as per Q&A 2946)
Old answer published until 01/02/2024:
Both the LOG and BV1213 are correct. Namely, column C0120 should be empty for CIC categories mentioned in the LOG (##71, ##(75, ##8# and ##9#). However, for other CIC codes, it is still possible no custodian is present. Therefore, “No custodian" option allows EIOPA to explicitly confirm that none is present for given row, limiting the chance of unnoticed omission.