Question ID: 425
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Template: S.01.03
Status: Final
Date of submission: 24 Nov 2015
Question
1. It is implied from the log files for (s.01.03.01/04) that BI entries are made for the 'Remaining Part' of the business. What should C0040, C0050 be set to as there is not a fund number or description? What should C0070 be set to (neither option 1 or 2 seems applicable; however it is a closed list)? What should C0070 and C0080 be set to .. blank/null would seem appropriate but it is not explicitly stated so and again these are to be populated from closed lists.
2. Mother funds. The logs imply that there is only one level of mother fund... i.e. a fund might have sub-funds, but a given sub-fund cannot further be defined in terms of a further level of sub-funds (i.e. nested levels). Is that interpretation correct? if a fund is marked in C0070 is set to 1 (Fund with other funds embedded) then C0080 is set to either 1 (material) or 2 (not material) ... but the child funds of that fund do not need to have set whether they themselves are material or not (i.e. C0070 is left blank/null).
3. The log says: In case a ring-fenced fund has a matching portfolio not covering the full RFF three funds have to be identified, one for the RFF, other for the MAP inside the RFF and other for the remaining part of the fund (vice-versa for the situations where a MAP has a RFF).
So if we had a fund (for example let’s call it Fund00001) that does not strictly have sub-funds but which has a MAP within it; then you suggest there are three entries in S.01.03. namely
Fund00001.Full
Fund00001.MAP
Fund00001.RFF_RP
Does the Fund0001.Full row have C0060 set to 1, is C0070 set to 2? C0080 set to 1 or 2 (given that C0080 should only be reported for Mother funds)
Does the Fund00001.RFF_RP have C0060 set to 3 (remaining part ) or 2 RFF?
For the second table (List of RFF/MAP with sub RFF/MAP) should there be entries for Fund00001.MAP and Fund00001.RFF_RP rows and if so please confirm the setting to be used for C0120
If the assumptions above are not correct, can you provide a worked example of a fund which splits into MAP and remaining RFF parts.
EIOPA answer
1. In S.01.03 the “remaining part” as generally used should not be reported. In specific cases where a ring-fenced fund has a matching portfolio not covering the full RFF three funds have to be identified, one for the RFF, other for the MAP inside the RFF and other for the remaining part of the fund (vice-versa for the situations where a MAP has a RFF). The “remaining part of the fund” is still a RFF. For the “remaining part of the fund”, C0040/C0050 should be filled with the code of each part. As they have to be reported separately (due to RFF and MAP requirements) all parts of the fund need to have specific codes. Still for the “Remaining part of a fund” C0060 should be “3”, C0070 should be “2” and C0080 is to be left blank.
2. In fact the EIOPA considers that only one fund is the “mother” and all other sub-funds have to be reported as “sons” of that fund. The materiality is only assessed to the mother fund and should not be reported for the others (as said in the LOG)
3. For the Fund0001.Full row C0060 should be “1”, C0070 should be “1” (NOT “2”) and C0080 set to 1 or 2 (given that C0080 should only be reported for Mother funds)
For the Fund00001.RFF_RP row C0060 should be “3” – Remaining part of a fund (but still RFF, it is not the “remaining part of the company”)
Entry of MAP: C0060 should be “2”; C0070 should be “2”, and C0080 should not reported
For the second table (List of RFF/MAP with sub RFF/MAP) there should be entries for Fund00001.MAP and Fund00001.RFF_RP rows:
C0100 code of RFF
C0110 code of each sub-fund (MAP or remaining part of a fund) – one line per sub-fund
C0120 should be “2” for the MAP and “1” for the remaining part of the fund.