We are seeking clearance regarding the reporting of the Total Solvency II Amount for Futures as a zero balance. The zero balances relate to futures and cleared interest rate swap derivatives, which are shown in both the IFRS and Solvency II Balance Sheet with a fair value of zero, because they are cleared/margined daily by a central counterparty. To avoid double counting (cash and market value of the swap) book value/ market value is set to zero. Our current approach reflects the fact that centrally cleared futures and interest rate swaps are marked to market daily, with the market value transferred via variation margin. As a result, these positions fall to either a receivable or payable at any point in time, and we do not maintain a separate Solvency II fair value for each individual contract. However a local regulator of an enterprise within our group is referring to Article 75 of Directive 2009/138/EC, ie. “valued at the amount for which they could be exchanged between knowledgeable willing parties in an arm’s length transaction” and asks us to report the fair value of these instruments. Can EIOPA please take a postition on whether the reporting of a zero balance is correct or even wanted or does EIOPA agree with the local requlators request to report the fair value of these futures?