Question ID: 72
Regulation Reference: Guidelines on submission of information to NCAs (Preparatory phase)
Article: 35
Template: S.06.02
Status: Final
Date of submission: 06 Jun 2014
Question
In relation to Assets-D1 (S.06.02), it is said in the definition of cell A6 (Asset pledged as collateral) that it gives the supervisor information about “assets kept in the undertaking balance-sheet and that are in the scope of reporting in template AS-D6”.
However, in the General Comment of QRT Assets-D6 it is stated that “this template includes all off-balance sheet type of investments (incl. all properties and participations, structured products, loans, bank deposits, etc) held as collateral”.
Based on these definitions, we understand that Assets-D1 (S.06.02) contains all assets (except derivatives) which are on balance-sheet and some of them may be pledged as collateral; Assets-D6 contains all assets which are held as collateral and are off balance-sheet. Therefore we think there can be no link between those QRTs through cell A6.
Can you please confirm if our understanding is correct?
Could you clarify the link with other QRTs (eg. Assets-D5 or BS-C1B)?
EIOPA answer
In fact the situation was not clear and we will make it clear in the reporting ITS.
EIOPA clarifies that:
- The template “Assets held as collateral” should include only off-balance sheet items and therefore the description of cell A6 in S.06.02 have to be amended;
- Structured products are reported in both S.06.02 and in the template “Structured products” (see July 2012 reporting publication);
- Securities lendings and repos are also reported in S.06.02 if according to the contract the undertaking keeps the right to freely dispose the assets subject to those contracts and if, as a consequence, they are recognised in the Balance-Sheet.