Question ID: 735
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Template: S.12.01
Status: Final
Date of submission: 05 Aug 2016
Question
I have a question on the Surrender Value disclosure in R0300 of template S.12.01.01, specifically for “Index-linked and unit-linked insurance” business in column C0030. We have assumed that this column captures both pure unit-linked business and the unit-linked portion of UWP business. We are assuming that the surrender value disclosure in this cell captures the surrender value for all business within this line of business (the surrender value is effectively equal to the unitised fund value for all business in this column). However, I notice that recent EIOPA Q&A responses for the S.41.01.11 Surrender Rate Financial Stability QRT clarifies that this S.41.01.11 surrender rate disclosure should specifically exclude pure unit-linked products.
Can you please clarify whether the S.12.01.01 Surrender Value disclosure in R0300 / C0030 should capture all business in the “Index-linked and unit-linked insurance” column (pure unit-linked business and the unit-linked component of UWP business), or should the Surrender Value disclosure exclude pure unit-linked business (consistent with recent EIOPA advice for S.41.01.11)?
EIOPA answer
In this case EIOPA took different approaches in prudential and financial stability reporting requirements.
In S.41.01.11 we have stated that “pure unit linked products are to be excluded”. This statement should only be considered for the purposes of financial stability reporting.
In S.12.01 we do expect to see the surrender value of the unit-linked products reported. Unless a specific surrender value has been specified in the contract, this should be understood as the unitised fund value, where applicable corrected by commissions as defined contractually in case of a surrender of the product. This value should be reported in the columns of unit linked contracts, regardless if they are pure unit linked or are linked to other contracts.
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