Question ID: 510
Regulation Reference: (EU) No 2015/2452 - procedures, formats and templates of the solvency and financial condition report
Article: 51
Status: Final
Date of submission: 10 Feb 2016
Question
There is a conflict with in the Own funds template where there is a requirement to split the disclosure of Own funds of other financial sectors into the different tiers ie Tier 1 unrestricted, Tier 1 restricted and Tier 2 only. The log files note that information populated in these cells should be linked to the numbers added back in R0410 – R0440.
In accordance to above, the template blocks out R410/R420 and R440 but missed the blocking of R430 related to Non regulated entities carrying out financial activities. This unblocking of R430 is in conflict to the log files and to the sub total provided in R440.
Hence it is assumed that there is an error in the template, and the intention was also to block R430 data entry for Tier 3.
EIOPA answer
We believe that the question is addressing R0420 (Institutions for occupational retirement provision), for which in fact Tier 3 own funds might be reported (and not R0430).
However, in fact there is a mistake in R0440 where C0050 should in fact be open (not crossed out) to allow the reporting of the amount reported in R0420.
A similar mistake was found in R0230 where the column of Tier 3 (C0050) should also be open (not crossed out)
We will try to incorporate this amendment in an ERRATA and amend XBRL taxonomy accordingly.