Question ID: 595
Regulation Reference: (EU) No 2015/2452 - procedures, formats and templates of the solvency and financial condition report
Article: 35
Template: S.23.01
Status: Final
Date of submission: 01 Apr 2016
Question
In the final QRT' for S.23.01.04 released in the ITS R0220 for own funds not recognised by the reconciliation reserve, we note that you have removed the ability to add this to Tier 1, which was allowed previosly. This means that it can only be added to c010 the total. We are unclear to the logic and the rationale why it can not be disclosed as a tier as it means that the sum of the tiers no longer add to the total.
EIOPA answer
Technically the item “Own funds from the financial statements that shall not be represented by the reconciliation reserve and do not meet the criteria to be classified as Solvency II own funds” is not classifiable by tiers. Therefore only the C0010 on the total is required to be reported.
It is true that the sum of the tiers will not add to the total and this was duly considered in the validations.