Question ID: 35
Regulation Reference: Guidelines on submission of information to NCAs (Preparatory phase)
Article: 35
Template: S.23.01
Status: Final
Date of submission: 09 Jan 2015
Question
The “Appendix_3_Changes_LOGs.xls” “provides, for the templates applicable in the preparatory phase, explanations of the changes performed to the templates and LOG files from July 2012 to the ones published in CP-13/010 and separately from the ones published in CP-13/010 to the ones now published in the final Guideline.”
Regarding the identification of changes performed to the version published at July 2012 Final Report (i.e. “CP10 vs. CP13” changes), the worksheet ‘S.23.01’ (related to OF-B1) indicates that some information has been deleted “for groups”, in the “annual” format:
A77.1…G77.n : “In the Template OF B1 for groups (annual) , table "Description of subordinated MMA (solo) " wrongly included in group's template - it was deleted from the template”
A100.1 …F100.n : “In the Template OF B1 for groups (annual) , table "Description of subordinated liabilities (solo) " wrongly included in group's template - it was deleted from the template”
A506.1…..D510 : “In the Template OF B1 for groups (annual) , the section "Adjustment for participations" wrongly included in group's template - now deleted”
It appears that the same information has been deleted in the annual solo template as well – ‘OF-B1A-S.23.01.b’ - (without being noted so by EIOPA in the change log).
We would welcome confirmation that these information are:
1/ still required at solo level (in the annual OF-B1 format) and that the deletion from the templates file (Appendix 1) is a human error
2/ or not required during preparatory phase but required from 2016.
EIOPA answer
The referred cells were not deleted from the individual Own funds solo template. However, as stated in para. 3.108 of the Final Report of CP13/010: “In addition, due to data point modelling analysis, the own funds template will, for the future technical standard be split into 4 templates, without any change in the content. This split aims to have in a different template,
information on the “general information”, “movements” and on the “open lists”. For that reason, the templates: S.23.01.b and S.23.01.g, which represent the annual own funds template for individual and groups respectively, only reflect part of the annual version of own funds templates, as published in the Final Report in July 2012.”
The identified cells will be part of the individual template of own funds with information on “open lists”.