Question ID: 2753
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Reporting Templates
Article: ANNEX VI Definitions of the CIC Table
Template: S.02.01
Status: Final
Date of submission: 08 Aug 2023
Question
The new CIC 88 in Annex VI is defined as "Loans made to other natural persons. This class shall prevail over the ones above." Should the CIC 88 also apply to loans for policies if the loans is made to a natural person? If so, how does it have to be reported in S.02.01? Previously, there was a direct link between CIC 86 and R0240 in S.02.01.
Background of the question
We interpret the new CIC 88 to apply when a loan is made to an individual, regardless of whether it is a mortgage loan or loan on policies, since it shall prevail the other CICs.
EIOPA answer
Yes, CIC 88 shall apply to loans on policies when they are made to natural persons other than AMSB. On the reporting in S.02.01 in R0240 – Loans on policies, there should be Loans with CIC 86 or (CIC 87 or CIC 88 when the collateral is policies), while in R0250 there should be CIC 87 or CIC 88 when the collateral isn't policies. Regarding validation, R0240 + R0250 = CIC 86 + CIC 87 + CIC 88.