Question ID: 3048
Regulation Reference: Other
Topic: Reporting Templates
Template: E.04.01
Status: Final
Date of submission: 19 Mar 2024
Question
Considering ECB add-on report E.04.01 examples and methods E.04.01: It would be very helpful to present clear example of splitting inv. revenues to EoAoL- and TP-movements. UL part seems more straightforward. And not artificial example but a real one, with decisions on how you split revenues between EoAoL and TP -movements, also for many different years, where there are cases where EoAoL movement in total is negative, and also TP movement is highly negative (due to interest rate movements etc.). E.04.01: Many companies does not have clear way to split inv. revenues (or expenses) to EoAoL or TP. One would say that all revenues and expenses goes firstly to EoAoL and it’s not part of TP (attributed to policyholders) at all, but it’s not likely that this approach is not valid. It seems artificial to tie revenues or expenses to TP movements, because it is not clear at all for many companies. So, keeping this in mind, which of the following is better in your view o Holistic view: Would it make sense to use holistic approach and try to look TP movements and EoAoL movements and try to split revenues and expenses regarding to what is percent of TP-movements from total EoAoL movements? There has to be also ways to handle situations where movements are negative. o “Exact” view: If holistic approach is not allowed and not wanted then you’ll have to make a decision on how company uses revenues (and expenses) for each TP-movements. So you count for example following items to TP-movements that revenues partly (or totally) cover: Discretionary benefits (DB): one would have to look TP-movements due to DB (estimation error). TP has already some assumption of DB, so the key is estimation error. UL-returns: TP-movements due to UL estimation error, as in DB one has risk-free return assumption in TP_UL, so again important here is the estimation error. Unwinding of discount rate TP (s.29.03 R0060): this will affect to TP-movements for guaranteed business and is clearly part of TP. And in theory company covers this movement from inv. returns. Variation of Best Estimate due to changes in economic environment (s.29.03 R0070): if unwinding of discount rate is included how would you say that economic environment changes will not be attributed to policyholders. They will affect TP directly, and company covers these movements from inv. returns. what other TP-movements can be included here? o Is the holistic approximation better than the second one? In the second method one has to firstly decide whether revenues (or expenses) can cover listed TP-movements and after that decide of the volumes of how much revenues cover each of these. What about cases where interest rate movements affects heavily on TP, and TP movement is linked to this one figure, and it will decide how much is covered from revenues. I think that both approaches are problematic and reporting figures are done in many different ways. Maybe on average they would give some justified view on the question. On the other hand there is a risk that variation in reporting decisions are so high that reports fail to gather data that is wanted. So it would be great to have more specific instructions to this report also. Not to mention the purpose and the goal of this report.
EIOPA answer
Holistic reporting as described above, does not fit the aim of this template. As for the proposed “exact view”, please note that in template E.04.01 only information on investment revenues, thus dividends, rents and interests as reported in S.29.02 (R0070, R0080, R0090 and R0100) and investment expenses as reported in S.29.02 (R0050) should be reported. The mentioned TP movements as reported in S.29.03 should not be included in E.04.01. Discretionary benefits should only be included if they are dividends, rents, and interest.