Question ID: 535
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Template: S.06.02
Status: Final
Date of submission: 10 Feb 2016
Question
With certain fields there is no unambiguous specification for which CIC categories these are to be delivered or not but there are partly examples listed, which can be interpreted differently with respect to the exclusion of not listed options. For example, in the field C0360 (Duration) in the template S.06.02 only the following vague specification exists for the CIC category 4: "when applicable, e. g. for collective investment undertakings mainly invested in bonds".
Also for a collective investment undertaking, which does not invest primarily in bonds, a duration can be determined under certain conditions. Can this be delivered then also in such cases (e.g. for CIC 42 - Equity funds) in the template or are such records rejected then? Or more generally: Can fields also be delivered for assets for which no explicit requirement exists on the part of EIOPA as long as it is not expressly forbidden in the definition?
EIOPA answer
We do have some validations, e.g. for S.06.02.C0110, C0270, C0280 or C0390 for which no information should be reported depending on the CIC code (see BV4 to 6 or BV237). However in general, when it says “when applicable” the information should be reported if available. In the case referred to in the question the information on the Duration should be reported.
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