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European Insurance and Occupational Pensions Authority
 

2717

Q&A

Question ID: 2717

Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision

Topic: Reporting Templates

Template: S.30.03

Status: Revised

Date of submission: 23 Jun 2023

Question

Regards the changes to template (S.30.03) in 2.8 taxonomy, and the associate LOG guidance (in the draft business package supporting SII taxonomy 2.8.0). We would like to confirm the implication of the LOG guidance sentence for C0245: ""In case the treaty only includes one layer, this cell will be equal to C0250."" 1. We assume the reference to C0250 is a typo (C0250 is the Number of reinstatements), we believe C0240 was intended instead. Please confirm 2. We think this guidance would still apply where a layer covers the scenario in LOG guidance for C0070 Additional Remarks point 1: ""Where the reinsurance treaty provides cover for more than one line of business and the terms of cover differ between lines of business then the treaty needs to be specified over multiple rows"" In this case of a treaty with only one layer, it is reported over multiple rows but only for the overall row (C0070 = multiline) would C0240 be completed (as per Q&A # 912). We think in this scenario also C0245 would only be completed in the overall row. So we are not saying we see an issue with the guidance (because when C0240 if completed = C0245 which would also be completed and when C0240 is not completed also C0245 would not be completed), but we would appreciate confirmation you agree (that this guidance does apply also with the line of business breakdown scenario). 3. We foresee NCA plausibility tests for this new data point (because there are already many such tests for all the other pre-existing fields in this QRT) for the correct completion of C0245 i.e. that it is only completed with a different value to C240 where a treaty contains multiple layers and otherwise has a matching value. We first though seek confirmation of our underlying assumption: are we correct in thinking that C0030 should be the same for all rows relating to that layer e.g. including case with multiple line of business breakdown i.e. if a layer did cover more than one line of business and the terms of cover differ then in each row (one row for C0070 = “multiline” and a row for each line of business, C0070 specifying each) C0030 would still be the same for each row (as it is the same section of the treaty) and C0070 would indicate the different lines of business covered by this layer. C0040 and C0050 are not relevant for this discussion as they indicate how different treaties fit into an overall programme (as per Q&A #1829, although we think in practice these two columns are reported in inconsistent ways across the market). If that is the case then C0030 can indicate where a treaty has more than one layer; as only where there are different C0030 values for the same C0020 do we have different layers. Hence for each distinct C0020, if there is more than one distinct C0030 then we would NOT expect C0245 = C0250 for these different rows (because if the treaty has multiple layers then we must expect each layer to have lower maximum cover than the overall treaty, with the exception of unlimited cover, see next comment). This rule would be different if C0240 = -1, in which case C0245 can equal C0240, and in fact must equal C0240 for at least one record within this same treat (same C0020 value). Do you agree?

EIOPA answer

The answer has been revised on 12/12/2024:

First question: There is typo in the LOG of S.30.03 C0245, the reference should be to C0240 instead of C0250. Please also see Q&A 2692.

Second question: C0240 is to be reported by treaty and C0245 by layer of the treaty, not by LoB. Please also see Q&A 2692.

Third question: According to the LOG “Treaties with different conditions are considered different treaties for the submission of information and shall be reported in different sections" e.g., a treaty with a quota-share section and an XL section. Therefore, C0240 should include the maximum cover for the relevant section of the treaty, i.e., it is a total at C0030 level, not at C0020 level.  EIOPA agrees the progressive section number (C0030) should be the same for all LoBs within the same section. C0040 and C0050 are only relevant within the context of a wider reinsurance program, i.e., if the treaty does not belong to any reinsurance program, C0040 and C0050 should be empty. Therefore, the number of different sections (C0030) reported for a specific treaty (C0020) is not relevant to assess whether C0240 = C0245. C0240 should be equal to C0245 if the section of the treaty only has one layer.

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Previous answer published until 12/12/2024:

First question: There is typo in the LOG of S.30.03 C0245, the reference should be to C0240 instead of C0250. Please also see Q&A 2692.

Second question: C0240 and C0245 are to be reported by treaty, not by LoB. Please also see Q&A 982.

Third question: According to the LOG “Treaties with different conditions are considered different treaties for the submission of information and shall be reported in different sections" e.g., a treaty with a quota-share section and an XL section. Therefore, C0240 should include the maximum cover for the relevant section of the treaty, i.e., it is a total at C0030 level, not at C0020 level.  EIOPA agrees the progressive section number (C0030) should be the same for all LoBs within the same section. C0040 and C0050 are only relevant within the context of a wider reinsurance program, i.e., if the treaty does not belong to any reinsurance program, C0040 and C0050 should be empty. Therefore, the number of different sections (C0030) reported for a specific treaty (C0020) is not relevant to assess whether C0240 = C0245. C0240 should be equal to C0245 if the section of the treaty only has one layer.