Question ID: 3013
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Reporting Templates
Template: S.33.01, S.34.01
Status: Under Review
Date of submission: 23 Feb 2024
Question
1. in S.34.01, the guidance to C0085 reads like this field is only applicable to insurance holding companies and mixed financial holding companies: "Contribution of the solo notional SCR to the group SCR with regard to insurance holding companies and mixed financial holding companies" i.e excludes other types of entities that should be included in S.34.01 e.g. credit institutions,investment firms, financial institutions, alternative investment fund managers, UCITS management companies etc. Can EIOPA confirm that is the case? And if so is it the case that C0085 should be left empty (or with value 0) for such entities?
2. Further the S.33.01 C0270 and S.34.01 C0085 guidance for the calculation of SCRisolo says: "SCRisolo is the SCR at individual entity level of the participating undertaking and eachrelated insurance orreinsurance undertaking and third-country insurance and reinsurance undertaking included inthe calculation of the SCRdiversified". This specifically refers to insurance undertakings ie. and not holdings companies. Is that intended (because SCRdiversified includes such entities, via definition of DR Art 335(1)(a) and (c))?
3. Can you confirm the following relationships (assumes Standard Formula reporting ie S.25.01, but these references would be replaced with S.25.05 for non-standard Formula groups): Taking one specific example to see if I am on the right track, if we wanted to calculate C0270 for a particular row in S.33.01, and in this case from the matching row in S.32.01 (linking on id code), S.32.01 [C0260] is 1 i.e. full consolidation, then S.33.01 C0270 =S.33.01 C0120 (for the same row we are calculating) * S.25.01 C0100 R0220 / [SUM { S.33.01 C0120 where in S.32.01 matching row S.32.01 C0260 is category 1, 2 or 4 (these being the categories of insurer in S.33.01 that would be part of DR Art 336(a)) }+ SUM { S.34.01 C0060 where in S.32.01 matching row S.32.01 C0260 is category 1, 2 or 4 (these being the categories of holding company that would be part of DR Art 336(a)) } If you could kindly confirm this calculation or advise how (or even if) S.33.01 (and S.34.01) contribution of solo SCR to group SCR fields can be derived from other information already reporting in group QRTs that would be much appreciated.