Question ID: 524
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Template: S.29.01
Status: Final
Date of submission: 30 Aug 2016
Question
Will EIOPA be issuing further advice about completing the S29 templates ? I have asked a number of people in the industry and either they don't know or say that it will be very difficult. The instructions are confusing and it is not clear what cells should correspond to. For example on the S.29.01, R0180 would appear to be the sum of R0130 to R0170. But is this supposed to agree to R0080 ? If so, then this is itself confusing because this section (R130-R180) seems to be about the variation in the reconciliation reserve but R0130 is the variation in the excess of assets over liablities. This is a function of both the GAAP P&L (surplus funds) and the reconciliation reserve. Is R0250 a stand alone item or a sub-total ? Please can you give a worked example of how S.29.03 and S.29.04 are filled in for a non-life insurer as conceptually, I do not know what the template is seeking. For example, what is meant by variation in best estimate for risks accepted during the period ? And variation of BE due to year N projected ina dn out flows for risks accepted in prior periods ?
EIOPA answer
EIOPA is analysing the possibilities of providing further advice on this templates, besides the publication of Q&A.
Regarding your concrete questions:
- The variation of Reconciliation Reserve (S.29.01.R0180) corresponds to the value reported in R0130 minus R0140 to R0170. The value reported in R0180 is the same as in R0080/C0030. This is actually identified as “identical data point” in the “EIOPA_Solvency II_Validations”. This means that when reporting in XBRL actually it only needs to be reported once. The Excess of Assets over Liabilities (EoAoL) reported in R0130 is the Solvency II EoAoL, not a function of GAAP.
- S.29.01.R0250 is a standalone item and intends to allow the reporting of any remaining variation in the excess of assets over liabilities not captured by R0190 to R0240.
- In S.29.03: the aim is to strip out the reasons for the variation of the BE, i.e. if there was an increase of “x”, how much is related to new business, to claims paid, to changes in interest rate, etc.
o R0050: represents the amount of the BE at the end of the period that corresponds to contracts/risks that were accepted during the period (i.e. were not reflected in the opening BE)
o R0070: This row can be computed at year-end N-1 without knowledge of the reality as experienced during period N. It is the part of the best estimate (BE) resulting from discounted cash flows of period N – as reported at year-end N-1 – after unwinding the interest rate. A subtle distinction between R0070 and R0080 is simply that R0070 uses assumptions at year-end N-1 for period N, while R0080 is based on reality of period N.