Question ID: 389
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35, 9
Template: S.25.01
Status: Final
Date of submission: 06 Nov 2015
Question
Assuming that SCR undertaking is the sum of SCR ring-fenced funds and each matching adjustment portfolio and the remaining part, this triggers irrelevance in types of QRT "S.26.xx.b". Indeed in the "SCR-B2A-S.25.01.b" QRT, the log is clear on how to reconcile a SCR "as if no RFF exists" and a SCR without diversification effect across ring-fenced funds and each matching adjustment portfolio and the remaining part. But it seems that this reconciliation is explained and possible only at high level within the aggregation tree, but does not make sense anymore in an upstream sub-module level. So do the QRT "S.26.xx.b serie" still have to be published, or not ? according to [EIOPA-BoS-14/169, p.22], "In case of existence of ring-fenced funds or matching adjustment portfolios information defined in paragraph uu. shall not be reported for the entity as a whole", but it's strange that we don't find this important information is the header of "ITS Reporting Annex II_Article 9_S_26_01_LOG.doc" for example.
EIOPA answer
In fact the templates S.26 are not required at entity level in case of existence of ring-fenced funds or matching adjustment portfolios. The information is reflected in the articles of the draft ITS. The reporting requirements are defined by the ITS and don’t need to be repeated in the Instructions of the templates.
Please see points l., m. and n of article 14 of the Final report on public consultation No. 14/052 on the implementing technical standards on the templates for the submission of information to the supervisory authorities.