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European Insurance and Occupational Pensions Authority

430

Q&A

Question ID: 430

Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities

Article: 35

Template: S.30.01

Status: Final

Date of submission: 17 Dec 2015

Question

1. In respect of the QRTs is it possible to know the type and the length of each field (alphabetic, alphanumeric, numeric, number of chars) ?
2. In respect of QRT S.30.03 and S.30.04: after the first picture sent in April, has the Company to send possible variations during the year ? For example is it required to send a new picture relevant to possible changes in the first six months ? Which kind of changes are significant ? If changes have to be reported, which information have to be issued ? In respect of facultative cessions (QRT S.30.01 and S.30.02) only the first picture has to be sent ?
3. How does the Company manage possible correction in respect of wrong data sent in previous transmissions ? Or also in the current one ?
4. A facultative cession, in the “top ten”,  has inception date on the 1st of June 2016 and expiry date on the 30th of November 2016. Has it to be reported in the 2017 transmission (April 2017) ?
A facultative cession has inception date on the 15th of March 2017 and expiry date on the 14th of March 2018. Has it to be reported in the 2017 transmission (April 2017) or could it be reported in the transmission 2018 (April 2018) ?
5. In the QRT S.30.01 field 170, 2 premiums are mentioned: gross annual premium e written reinsurance premium? Which are the definitions for them? If the reported facultative cession covers 2 years, the premium has to be annualized ?
6. A policy covers 2 locations of the same insurer. The locations are in different countries. The policy is ceded in facultative. Is this considered 1 or 2 risks ?
7. How has the coded excess of loss (coded XL or “per-policy” XL) to be reported ? Is it possible to have an example ?
8. Please look at the example in the attached excel sheet. The Company issues 2 policies that cover in the same LoB Marine: Hull&Machinery, Increased Values, Hull War. There is 1 only insured and the facultative cessions as in the example. Questions: how many risks, how many facultative cessions ?
9. A Company has a combined profit commission working on 3 treaties (belonging to 3 different line of business). If the combined technical result of these 3 treaties exceeds the amount of EUR x, then the exceeding amount (combined technical result - x) is considered as a 100% super commission. How this situation has to be reported in the QRTs ?
10. In the QRT S.30.04 field 150. Is it possible to provide an example of the field item ?
11. For the non-life business there are 28 LoB. Why there are only 4 “Non-proportional xxxx reinsurance” LoB ? If the Company has an inward business non proportional relevant to “other motor” or “Workers' compensation” or “Credit and suretyship” and the Company reinsures it using a facultative cession. In which LoB has it to be reported ?

EIOPA answer

1. The type of each field may be identified in the Annotated templates. For example see S.30.01
Supervisory reporting - DPM and XBRL

2. The templates only have to be up-dated if material changes have occurred since last submission. In this case if reinsurance strategy changes materially or if the renovation of the reinsurance contracts is important. If for example, after the beginning of the year the ceding exposure changes significantly due to treaties/contracts not being renewed, the information would have to be up-dated. In case of an up-date the full template have to be submitted and the reference date should be the date for which the information relates to.
                                                                                     
3. Wrong data should always be amended and template re-submitted. Specific procedural aspects have to be seen with the National Supervisory Authority.

4. No, the template is prospective for the selected largest 10 facultative covers that have not yet expired at the start of the next reporting year whose period of validity includes or overlaps the next reporting year and are known when filling the template.

See previous answer. It has to be reported in April 2017.

5. The two are mentioned to cover both premiums already written and future premiums in case not written yet. Therefore the reference to “Expected gross annual” and “written reinsurance premium”. The definition of written premium from article 1(11) of Delegated Regulation 2015/35 should be used. The premium should be annualised.

6. It is considered 1 risk and the aggregate policy limits shall be considered. See comment in C0130 for clarification. Please note that if this implies two different currencies then C0120 needs to be considered.

7. If you mean e.g. in C0090 of S.30.03, as in C0140 of S.30.03, the close list is to be used.

8. As a general principle, the choices linked to the reporting of the risks depend on different criteria including risk categorisation, risk strategy, risk profile of the undertaking. Reading the Instructions of S.30.01 3 risks might be reported (Hull&Machinery, Increased Values, Hull War) and for Hull&Machinery 2 placements, Increased Values 3 placements and Hull War 5 placements.

9. In this case when filing in S.30.03 (assuming it is non-facultative as it is referring to treaties) treaty has to be identified as “37 – Multiline” in C0070 and template should be filled in considering: Where the reinsurance treaty provides cover for more than one line of business and the terms of cover differ between lines of business then the treaty needs to be specified over multiple rows. The first row entry for the treaty needs to be entered as “Multiline” that provides details of the overall terms of the treaty (such as deductibles and reinstatements), with the subsequent rows providing details of the individual terms of the reinsurance treaty to each relevant line of business.

10. For more information, please see report by the Financial Stability Board dated 8 June 2012: A Global Legal Entity Identifier for Financial Markets [http://www.leiroc.org/publications/gls/roc_20120608.pdf]
Examples might also be found in section V.1. of the document “Filing rules for Solvency II Reporting”

11. For the non-life business there are 28 LoB. Why there are only 4 “Non-proportional xxxx reinsurance” LoB ? If the Company has an inward business non proportional relevant to “other motor” or “Workers' compensation” or “Credit and suretyship” and the Company reinsures it using a facultative cession. In which LoB has it to be reported ?
The lines of business are defined in Annex I of the Delegated Regulation 2015/35.
“Other motor” is LoB “Non-proportional property reinsurance”
“Workers' compensation” is LoB “Non-proportional health reinsurance”
“Credit and suretyship” is LoB “Non-proportional property reinsurance”