Question ID: 3003
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Reporting Templates
Template: S.37.02
Status: Final
Date of submission: 15 Feb 2024
Question
The answer to Q&A#2630 is not 100% clear to us:"S.37 should include all type of exposures and is therefore not limited by information in S.06. However, when specific asset characteristics are not applicable (e.g. country of issuer is not applicable) to the assets following the assessment for S.06 this will also impact the tables under S.37 (e.g. table S.37.02.04.03 exposure by country will not reflect this asset but the asset still needs to be included in for example S.37.01.04.01, if significant)." ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ To be clear please: 1. An exposure to asset listed in S.06.02 for which country does not need to be reported in S.06.02 (eg CIC 9) should NOT be included in S.37.02.04.03 at all (as Q&A#2630 seems to suggest)? 2. What about assets in the balance sheet but not reported in S.06.02 e.g. Insurance and intermediary receivables? Should these be included in S.37.02.04 tables (none, some or all of them?) 3. Is look-through (for collective investment schemes) required for S.37.02.04 allocation?
EIOPA answer
1. Template S37.02.04.03 should capture the exposure by country, hence considers the country where the risk is located and should therefore be reported irrespectively of S.06.
2. S.37.02 should include all type of exposures and is therefore not limited to information provided in S.06.02.
3. Look through is applicable on a best effort basis.