Question ID: 437
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Status: Final
Date of submission: 19 Jan 2016
Question
With update as 07.08.2015 EIOPA has removed the requirement to report the so called "specific code" from columns C0020/C0030 with rationale "as it was not applicable" (cf. document "Mistakes amended in reporting and disclosure package_07082015.docx"). The requirement has not been removed from columns C0120/C0130 for group internal entities which raises the following questions:
1) Will the requirement to report a specific code persist in columns C0120/C0130?
If yes, we have the following follow-up questions regarding the construct "identification code of the parent undertaking + ISO 3166-1 alpha-2 code of the country of the undertaking + 5 digits" - apparently referring to group entities that hold the exposures to be reported on S.37.10 - as we see the need of a more detailed specification:
2) Which format is requested for “identification code of the parent undertaking”?
3) “Parent undertaking” of whom?
4) “Ultimate parent undertaking” or just “parent undertaking” requested?
5) “Code of the country” of the internal entity requested or of the ultimate parent of that group that reports the QRT?
EIOPA answer
The specific codes were deleted from C0020/C0030 as that column addresses the counterparty of the group which cannot be an entity within the group. The template covers all significant risk concentrations between entities in scope of group supervision and third parties. As the specific code only addresses undertakings within the group, it was deleted.
1) In C0120/C0130 the undertaking within the group needs to be identified and therefore the specific code applies.
2), 3) and 4) Should be the code of the parent undertaking as reported in S.01.02 (should be the same for all undertakings reported in C0110). Undertakings providing the data to their NCA with XBRL format also have to respect the format defined in the “EIOPA XBRL Filing Rules for Solvency II Reporting” (S.2.8.(c)) for the identification codes.
5) “Code of the country” is the code of the country of the entity referred to in C0110.