Question ID: 713
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Status: Final
Date of submission: 14 Dec 2016
Question
The LOG guidance for cell R0210 (Variations in capital basic own fund items and other items approved) states the following:
“This amount explains the part of the variation of Excess of Assets over Liabilities due to movements in “pure” capital items, such as Ordinary share capital (gross of own shares), Preference shares, Surplus funds”.
In our view, the variation in surplus funds is already captured as part of the other variation categories (i.e. within cells R0190, R0200 etc.) under the ‘Summary Analysis of Variation of Excess of Assets over Liabilities’. As such, including variation of surplus funds in R0210 would result in double count of variation relating to surplus funds.
Can EIOPA confirm if they agree with us and if so, can we ask EIOPA to make necessary amendments to the LOG guidance for cell R0210?
EIOPA answer
Contrary to what is requested in template S.23.02, where we are addressing the difference between SII and accounting valuation, in template S.29.01 we are adressing the variation between the beginning and the end of the year, but using Solvency II valuation only.
This means that the amount of Surplus Fund that is considered as Basic own fund under Solvency II should be captured only by R0210 and not by the previous cells. The amount of Surplus Fund that is not considered as Basic Own Fund under Solvency II is captured by R0190.