Question ID: 2980
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: Rejected
Date of submission: 12 Feb 2024
Question
From all of EIOPA's comments on the new column C0245, it seems the intention of S.30.03 C0245 is to indicate if, and to what extent, any layer is not 100% "covered" i.e. does C0245 equal C0230 or not (which is our understanding of EIOPA's answer to Insurance Europe Q&A document "ECO-SLV-23-165"). This being the case, for each treaty and section we have that information in S.30.04 C0100 so can EIOPA confirm the following is the expected reporting of C0245, taking into account C0230 and S.30.04 C0100. We would expect that the sum of S.30.04 C0100 for the matching treaty/section (and "Progressive number of surplus/layer in program" and "Quantity of surplus/layers in program") * C0230 = C0245. For example, if in S.30.04 there are 5 reinsurers in the panel which sum to 80% placement of the treaty, then for this given combination of C0020 through C0050, C0100 has a sum of 0.8. If S.30.03 C0230 (for a treaty in S.30.03 which is reporting only one (main) line of business) is 3M then C0245 should be 3M*0.8=2.4M Do EIOPA agree? A further to the above, one practical consideration for such a relationship is taking into account where S.30.03 has multiple rows due to different LoB. In this case we should only apply this relationship to the row where C0070 = "Multiline". Is that correct? The C0230 in this row would represent the limit of the layer?
EIOPA answer
This Q&A is rejected because after the publication of the Q&A 2718 it is no longer relevant. The recently published answer to Q&A 2718 clarified that C0100 should expressed as a relative percentage. According to the log file C0100 in S.30.04 should be expressed as an absolute percentage, however, C0100 is consistently used across the log file as a relative percentage (C0110 and C0160). Therefore, the relation suggested in the question cannot hold true.