Question ID: 548
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Status: Final
Date of submission: 05 Feb 2016
Question
Two questions:
1) Applying the country reporting threshold brings more complexity and effort than otherwise (additional sorting and aggregation process after the first aggregation process by Asset Category / Currency / Country of Issuer. Indeed, when recieving look-though data from an asset manager, the whole portfolio is provided. What is the benefit / logic of introducing an additional process for reducing the granularity of data that is already in our possession. Easier for undertakings to send everything. Also guidance is missing as to how to treat liabilities in this whole "sorting" process to get to the 90% threshold.
2) Lastly, this template assumes that the data recieved from the asset managers is 100% clean. For eg. no closed list value is foreseen for missing countries values. Undertakings cannot afford to complete missing information by fetching it from data providers. It would be good to foresee a "Missing" code at the very least for the country. Alternatively, could undertakings use the AA value or the XA value in cases where the country is missing and cannot be easily extracted from the ISIN or the CIC (when received by the asset managers ...)?
EIOPA answer
EIOPA doesn’t disagree but this template was subject to public consultation and comments from industry suggested otherwise. This was why the final outcome was to keep the information on Asset categories and Currency aggregated.
The thresholds have to be calculated using the Solvency II value of the Collective Investment Undertaking as reported in template S.06.02, i.e. considering the liabilities if any.
We assume that at least for 90% of the fund there is the identification of the country. In the exceptional circumstance where the threshold by country is not complied with due to lack of information the issue has to be considered from a risk management perspective by the undertaking and undertaking should contact the national supervisory authority as it refers to a non-compliance with the Technical Standard. It is understood that information by country is needed for risk management purposes. If no information is available the column should be left empty.