Question ID: 2722
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Reporting Templates
Article: 35 of SII Directive
Template: S.02.01
Status: Final
Date of submission: 26 Jun 2023
Question
Regarding the new reporting requirements (taxonomy 2.8.0) we ask for a clarification on the ECB add-on in S.02.01 (SE.02.01). In the liability part are requested the non-negotiable instruments held by credit institution / by non-credit institution (fields: ER0851 to ER0856); 1) we need more details on non-negotiable instruments category, could you please clarify which type of instruments are non-negotiable? 2) Could you please indicate if the non-negotiable instruments are a sub-total of which category? at the moment the technical specification indicates only Sub-liabilities = Sub.liabilities in basic own fund+ Sub.liabilities not in basic own fund.
EIOPA answer
1) Non-negotiable debt instruments are instruments where the transfer of legal ownership is subject to restrictions which imply that they cannot be marketed or, although technically negotiable, cannot be traded owing to the absence of an organised market.
Examples of such instruments are non-negotiable loans, borrower's notes, non-negotiable debt securities, non-negotiable money market securities, registered bonds (in the sense of “Namensschuldverschreibungen" (“N-bonds") or equivalent non-negotiable instruments)
One concrete case is the following: Two credit institutions granted a loan to an insurance corporation. The insurance corporation issued securities and the holders of securities are the two credit institutions granting the loan.
2) Non-negotiable instruments is an of-which of subordinated liabilities.