Question ID: 554
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 18, 34
Status: Final
Date of submission: 16 Feb 2017
Question
1) Article 18 (1) and Article 34(1) for Groups requires submission of QRTs re content of submission and SCR for each material matching adjustment portfolios (MAP), each material ring fenced fund (RFF) and the remaining part. However Article 18 (2) and Article 34 (2) only requires a balance sheet to be submitted for material RFFs and the remaining part. Therefore please confirm no separate balance sheet is required to be submitted for matching adjustment portfolios?
2) is the definition of remaining part consistent throughout all Pillar 3 reporting, ie balance sheet and SCR QRTs do not have different interpretations
3) Please can you also clarify what the remaining part means for both Solo and Group BALANCE SHEET reporting. We think there a number of interpretations below:
a) It is the non material RFF and MAPs only;
b) It is the non MAP non profit funds and shareholder funds only;
c) It is all other funds within the Solo/Group balance sheet so includes the non material RFF, MAPs, non matching adjustment non profit funds, shareholder funds of the insurance undertakings and the group would also include any data for all other entities within the scope of the group . This total wouldn’t agree to the balance sheet QRT though as it doesn’t include for solo any interfund eliminations and for group any consolidation adjustments.
d) For group it is (c) but also includes any consolidation adjustments and therefore the total of the RFF and Remaining Part balance sheets agree to the total group balance sheet;
e) For solo entities it is (c) but includes any inter fund adjustments and therefore the total of the RFF and Remaining Part balance sheetS agree to the total solo balance sheet,
4) Is there a definition of “material” in this context?
EIOPA answer
Please note that as a result of Q&A 915 the answer to Q&A 554 in point 3 was amended as follows on 16 February 2017:
1) We confirm that submission of a separate balance sheet for matching adjustment portfolios is not required.
2) The "remaining part" is used consistently in all QRTs, in accordance with Article 217 of the Commission Delegated Regulation 2015/35.
3) As regards the balance sheet, the remaining part covers all elements except all material ring-fenced funds and all matching adjustment portfolios. From a group perspective, the remaining part should be adjusted and should be net of intra-group transactions that do not impact any RFF or MAP, as provided in GL 15 of EIOPA Guideline on group solvency. In all cases the balance-sheet for the solo from an entity level should match the total of the BS for all material RFF and remaining part, in the cases where there are no MAP. If there are MAP, as it is not required to report the BS for them, the balance-sheet for the solo from an entity level would not match the total of the BS reported for the RFF and remaining part.
4) As regards the materiality of ring-fenced funds, please see Guideline 5 from EIOPA "Guidelines on ring-fenced funds".