Question ID: 587
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Template: S.02.01
Status: Final
Date of submission: 09 Mar 2016
Question
Question 1
About the basic principal on look through reporting: According to our knowledge look through reporting concerns both non-unit linked and unit linked investments. Is the main principle in look through reporting that non-unit linked and unit linked instruments are on the report without any special sign telling, which instrument is unit linked and which one non-unit linked?
About cases where non unit linked and unit linked portfolio has the same instrument:
How to report look through assets if same instrument is in “Unit Linked” portfolio and “Non-unit linked portfolio” (same instrument in assets list twice, difference is field Unit Linked “Y/N”) ? Should these be grouped by instrument (unit linked and non-unit linked together) as in the look-through report there is no portfolio identification field (“UL”/ “non-UL”)?
Question 2
In the quidelines it is stated:
Quarterly information shall only be reported when the ratio of collective investments undertakings held by the undertaking to total investments, measured as the ratio between item C0010/R0180 of template S.02.01 plus collective investments undertakings included in item C0010/R0220 of template S.02.01 plus collective investments undertakings included in item C0010/R0090 and the sum of item C0010/R0070 and C0010/RC0220 of template S.02.01, is higher than 30%.
What if the ratio differs quarterly to quarterly and is sometimes over and sometimes less than 30 % ? What if the Q4 ratio is under 30 %, is this reported or not ? Annual report is needed in any case ?
EIOPA answer
Question 1:
Correct, in template S.06.03 there is no distinction for the unit linked. The look-through is done by instrument. If a CIU is hold both in unit linked portfolio and non-unit linked portfolio, it should appear in S.06.03 only once (with the look-through required) covering the total amount invested in that CIU.
Question 2:
If the threshold is different from quarter to quarter the template should only be submitted in relation to the quarters where the threshold is met.
In fact, template S.06.03 has to be submitted annually by all undertakings without application of any threshold, unless exempted under article 35 (6) to (8) or already reported under quarter 4.