Question ID: 3288
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Reporting Templates
Template: S.06.03
Status: Final
Date of submission: 11 Mar 2025
Question
The look-through in S0603 should identify at least 90% of the total value of the funds less CIC 8 and 9 with regards to countries and 90% of the total value of funds with regards to currencies. Therefore, we have two questions: 1) Which country should be applied for CIC 0 assets, e.g. physical commodities (gold), crypto currencies (bitcoin) or artworks (paintings)? 2) Which currency should be applied for such assets?
EIOPA answer
In the absence of explicit guidance on the allocation of country and currency for assets classified under CIC 0, reporting entities are expected to apply a consistent, well-reasoned, and documented methodology.
For the identification of countries, the look–through shall be implemented in order to identify the exposures of 90 % of the total value of the funds minus the amounts relating to CIC 8 and 9, and for the identification of currencies the look–through shall be implemented in order to identify the exposures of 90 % of the total value of the funds. In order to fulfil this requirement, entities need to include CIC 0 assets in the 90% calculation. These assets need to be assigned a country and a currency on a best-effort basis, considering the nature and characteristics of the respective asset. E. g. it could be checked if for physical commodities (and similar physical assets) the country of custody can be used.
While EIOPA does not prescribe a specific treatment, in light of the above considerations, using the reporting currency of the undertaking might be an appropriate option for assigning a currency to CIC 0 assets.