Question ID: 34
Regulation Reference: Guidelines on submission of information to NCAs (Preparatory phase)
Article: 35
Template: S.01.02
Status: Final
Date of submission: 06 Mar 2014
Question
1. Paragraph 2 of Technical Annex I of Guidelines on Submission of Information to National Competent Authorities issued by the European Insurance and Occupational Pensions Authority (EIOPA) on 31 October 2013 - hereinafter referred to as ‘the Guidelines’ –states that new template S.01.02 (presumably both S.01.02.a and S.01.02.b) maps to old template BI. However, I cannot find a reference to template BI in any of the following:
a. Quarterly_Reporting_Solo_Templates(1)
b. Annual_Reporting_Solo_Templates(1)
c. Quarterly_Reporting_Group_Templates_01(1)
d. Annual_Reporting_Group_Templates(1)
I would be grateful for some clarity.
2. Paragraph 1.58 of the Guidelines refers to old template TP – F1Q as S.12.01.a.
Paragraph 10 of Technical Annex I of the Guidelines refers to it as S.14.01.a.
Technical Annex II of the Guidelines refers to it as S.12.01.a.
I would be grateful for some clarity.
3. Paragraph 1.50 of the Guidelines refers to old template TP – F1 as S.12.01.b.
Paragraph 11 of Technical Annex I of the Guidelines refers to it as S.14.01.b.
Technical Annex II of the Guidelines refers to it as S.12.01.b.
I would be grateful for some clarity.
4. Will the Preparatory Phase template names be used post-implementation ? (It is not made clear in the Guidelines if the new template names are for the Preparatory Phase only or will be used post-implementation.)
5. If the template names to be used post-implementation are the same as those to be used in the Preparatory Phase, it would be useful to have a complete mapping of old names to new ones including those templates that are not required in the Preparatory Phase but which will be required post-implementation since neither Technical Annex I nor Technical Annex II contain this information.
6. If, on the other hand, the template names to be used post-implementation are not the same as those to be used in the Preparatory Phase, what nomenclature is to be used post-implementation?
7. At least one of the cross-template checks provided in Technical Annex VI of the Guidelines appears to be inaccurate as follows:
a. CAS 30 is S.02.01.b.L7A = S.12.01.b.A1+S.12.01.b.A5+S.12.01.b.A6+S.12.01.b.A7
but I think it should be S.02.01.b.L7A = S.12.01.b.A1+S.12.01.b.A3+S.12.01.b.A5+S.12.01.b.A6+S.12.01.b.A7
or simply S.02.01.b.L7A = S.12.01.b.A9
b. CQS 16 is S.02.01.a.L7A = S.12.01.a.A1+S.12.01.a.A5+S.12.01.a.A6+S.12.01.a.A7
but I think it should be S.02.01.a.L7A = S.12.01.a.A1+S.12.01.a.A3+S.12.01.a.A5+S.12.01.a.A6+S.12.01.a.A7
or simply S.02.01.a.L7A = S.12.01.a.A9
If I am correct and there are some inaccuracies in these cross-template checks, can you let me know what programme you have in place for issue of errata, please?
EIOPA answer
1. BI stands for Basic Information and that was the original name of the template using the old criteria to name templates. It is true that for the public this template is new and therefore never had an “old” name. Sorry for the confusion.
2. and 3. The correct name of TP – F1Q is S.12.01.a. and of TP – F1 is S.12.01.b.. There was a mistake in Annex I that was corrected through the ERRATA published at EIOPA website.
4. The new names will be used for the future Technical standard on regular reporting.
5. EIOPA understands the request and will analyse the possibility to publish such a table as soon as possible.
7. CAS30 and CQS16 are correct. L7A from S.02.01 should not include A3 (Index-linked and unit-linked insurance) from S.12.01 as that amount is included in L10A of S.02.01. Also, it is in the LOG of S.02.01.b that L7A is part of L7 and L7 is defined as “TP life (excluding health and index-linked and unit linked)”.