Question ID: 360
Regulation Reference: Guidelines on the Forward looking assessment of own risks
Article: 35
Template: S.06.02
Status: Final
Date of submission: 24 Aug 2018
Question
How should the group-reporting of D1 (S.06.02) be filled out when method 1 is used for consolidation purpose?
Take an insurance group that consists of one insurance company (holding insurance company) that owns 100 percent in another insurance company and besides that also owns other subsidiaries, for example companies that invest in properties. The insurance subsidiary also owns other subsidiaries.
In the LOG of D1 its stated that Item ‘Legal name of the undertaking’ shall not be reported when method 1 is used. Does this also mean that Identification code of the undertaking should not be filled?
For instance, if we have the same equity in both insurance companies and we consolidate those we could either report one consolidated line in the report of that equity or report two lines separated by Identification code of the undertaking (we would always split based on portfolio (life/non-life/general)). However each line will also be reported in each solo-entity so it doesn’t make much sense.
The other case is properties or other assets that are owned by subsidiaries to the insurance holding company or the insurance company owned by the insurance holding company. These subsidiaries are consolidated into the group and after elimination we end up with reporting a property and in some cases loans/deposits. Should we in this case report the subsidiaries (that owns the property) Identification code of the undertaking or should we put the insurance company that owns the subsidiary? (Could also be an example were the insurance holding company owns another insurance company which owns a subsidiary which owns a property (or another asset).)
EIOPA answer
As clarified in the Instructions of the template (in preparatory phase as part of Annex I of the Guidelines on Submission of information) where method 1 is used exclusively, the reporting shall reflect the consolidated position of the assets net of intra-group transactions held within the group. The report shall be made as follows:
- Item ‘Legal name of the undertaking – C0010’ and ‘Identification code of the undertaking – C0020’ shall not be reported;
- The assets held by the participating insurance and reinsurance undertakings or insurance holding companies or mixed-financial holding companies shall be reported item by item;
- The assets held by undertakings consolidated in accordance with Article 335 a-b-c of Delegated Regulation 2015/35 shall be reported item by item;
- Participations in undertakings consolidated in accordance with Article 335 d-e-f of Delegated Regulation 2015/35 shall be reported in one line and identify it by using the available options in cell C0240.
As regards the “Identification code of the undertaking” (C0020) this was in fact only clarified in the final version of the LOG.