Question ID: 318
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Template: S.36.03
Status: Final
Date of submission: 24 Nov 2015
Question
According to the LOG File Wording (CP-14-052-ITS), it is to assume that the template S.36.03. is not
applicable to facultative reinsurance and co-insurance contracts. Please confirm our understanding.
In case this template has yet to be submitted for the facultative reinsurance as well as co-insurance contracts,
Please provide us with a detailed guidance how the field C0130 (K6 - Net Receivables) is to be calculated for those
contracts. Furthermore, we are not quite sure where to place co-insurance contracts in the classification provided by
"Type of reinsurance contract/treaty" (C0110 - I6) in this case.
EIOPA answer
The template should include all internal reinsurance within the group, including facultative reinsurance.
Regarding co-insurance:
- Co-insurance, in the meaning of several undertakings within the same group performing co-insurance (direct business) is not considered as internal reinsurance;
- Co-reinsurance, in the meaning of several undertakings within the same group assuming risks from and entity outside the group, is not considered as internal reinsurance
- Co-reinsurance, in the meaning of several undertakings within the same group assuming risks from another group entity, is considered as internal reinsurance and should be reported in S.36.03
In the case of internal co-reinsurance (in the meaning of several undertakings within the same group assuming risks from another group entity), it should be reported separately for each (re)insurance undertaking belonging to the same group since in a co-reinsurance contract the insured sum is split in clear separate quota per each co-reinsurance undertaking, only if cumulatively the sum insured “internally” exceeds the thresholds defined for significant IGT, very significant IGT and IGT required to be reported in all circumstances.
The calculation of the Net receivables (C0130) should reflect the amount described in the Instructions: claims paid by the insurer but not yet reimbursed by the reinsurer + commissions to be paid by the reinsurer + other receivables minus debts to the reinsurer. The type of reinsurance contract/ treaty (C0110) should indicate the type of contract/treaty entered into by the co-reinsurers.
Any further doubt should be described in more detail.