Question ID: 2730
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Reporting Templates
Article: N/A
Template: S.37.01
Status: Final
Date of submission: 05 Jul 2023
Question
We have a question relating to cell C240 in the S.37.01 (the version of the QRT, following the adoption of the Commission Implementing regulation (EU) 2023/894). We have interpreted that “guarantees and commitments” in the cell C0240 also may include “assets in the balance sheet that are collateral pledged”. However – there is an item we wonder whether it should be excluded from the scope in that case – that is assets that are used (or "pledged as collateral") to cover the technical provisions and recorded in the “special register”. Given the specific nature of the “special register”, our interpretation would be to exclude assets that are used (or "pledged as collateral") to cover the technical provisions and recorded in the “special register” from the scope of C0240 in QRT S.37.01. Would this interpretation be correct?
Background of the question
Our question is related to EIOPA Q&A ID #2096, as this question also is in regards to assets recorded in the “special register”. The background information provided in that question regarding how the legislation for “special register” has been implemented in Sweden (for insurance undertakings / under the Solvency II directive) is also relevant in the case of our question.
EIOPA answer
Consistently with the answer provided to Q&A 2096, asset in the “special register" should not be pledged as collateral, therefore not included in the scope of C0240 in S.37.01.