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European Insurance and Occupational Pensions Authority
 

2978

Q&A

Question ID: 2978

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: Final

Date of submission: 11 Feb 2024

Question

We would like a worked example of a treaty with multiple layers as there is still much doubt as to how to fill certain columns for such a case. For this example please assume the treaty is:1. XoL with 3 layers: 2m XS 1m, 2m XS 3m, 4m xs 5m2. no reinstatements3. NOT part of a wider reinsurance program (so as per Q&A#2692, C0040 and C0050 are empty). 4. Only one line of business is covered by the treaty Q&A1961 indicated that if a treaty has multiple layers then these should be reported "one by one". So we would expect our example above to be: - reported on 3 lines. - all 3 lines should have the same C0010, C0020, C0070 and C0240 (being 8m) C0030 being different for each line (going 1 through 3), C0040 and C0050 to be blank for all 3 lines- 1st line (2m XS 1m) should have C0190 = 1, C0210 = 3, C0230 = 2 and C0245 a value between 0 and max of 2 (reflecting EIOPA answers to Insurance Europe paper "ECO-SLV-23-165" which stated: "In some non-proportional treaties, the excess is only partially covered. For example, an XL treaty may cover up to 200 in excess of 150, but providing a limited coverage of the excess, e.g., 80%. Therefore, C0210 would be 200, but C0245 would be 80% * 200 = 160.))- 2nd line (2m XS 3m) should have C0190 = 3, C0210 = 5, C0230 = 3 and C0245 a value between 0 and max of 2 - 3rd line (4m XS 5m) should have C0190 = 5, C0210 = 9, C0230 = 4 and C0245 a value between 0 and max of 4 Other columns would also be filled for these rows but the above focuses on the key columns where doubt exists.

Background of the question

Looking the ITS and Q&A's we have found interpreting terms like treaty, section and layer difficult as they can mean different things in different contexts. e.g. a typical treaty has several layers but in S.30.03 C0040 and C0050 are used to "layer" treaties into an overall program. Further, it seems EIOPA wishes the field C0030 "section" to sub-divide treaties with multiple layers but this is complicated by the use of section to sub-divide by Line of business (as well or instead?). Therefore we felt having a basic worked example set out would be the best way of resolving some of these doubts.

EIOPA answer

The description in the question is correct except for C0240. Please note that, according to the LOG in C0030, “Treaties with different conditions are considered different treaties for the submission of information and shall be reported in different sections". Therefore, C0240 is the maximum cover at C0030 level, not at C0020 level, i.e., it is the maximum cover of the section. Please also see Q&A 2692.


Please note that S.30.01 to S.30.04 templates will be reviewed in the next ITS amendment.