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European Insurance and Occupational Pensions Authority
 

3178

Q&A

Question ID: 3178

Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision

Topic: Reporting Templates

Template: S.32.01, S.36.01, S.36.02, S.36.03, S.36.04, S.36.05

Status: Final

Date of submission: 25 Oct 2024

Question

Can we get clarification on the completeness check that could be performed between entities reported in S.36.01 through S.36.07 vs S.32.01. For example, entities reported in S.36.01 C0030 (Identification code for investor/ lender) and C0060 (Identification code for issuer / borrower) should (given then should both be entities within the group as the template is reported intra-group transactions) both be included in S.32.01 C0020 (Identification code of the undertaking). The exception to the above rule would be for an entity that has been sold during the reporting period. As per Q&A#1962 this ITG should be included within S.36.01 but that entity will not be in S.32.01 at the reporting reference date. If you could confirm the above and that the general situation should be the same for the other ITG QRTs in addition to S.36.01 i.e S.36.02 through S.36.07)?

EIOPA answer

EIOPA confirms that in general the list of undertakings listed in S.36 templates and S.32 should match. However, there can be a situation as indicated in which an entity no longer reported in S.32 while the relevant transaction should still be reflected in S.36.​