Question ID: 746
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Template: S.20.01
Status: Final
Date of submission: 14 Sep 2016
Question
Annex II, log file “ITS Reporting Annex II_S_20_01_LOG_clean.docx” states that the amounts have to be net of subrogation. Often companies set the case status to “settled” when the obligations to the beneficiary are discharged, hence when the claim is indemnified. However, such companies can still carry recovery provisions for a claim after settlement. Where in the template recovery provisions for settled claims should be reported?
EIOPA answer
I believe this is a terminology question. The expression “settle” is used regarding obligations while we use the expression “close” regarding the process to manage the claim.
For the definition of “close claim” undertakings will use their specific definition or, if available, specification existing at national level (for instance requirement laid down by the National Supervisory Authority) as stated in the general comments.
Regarding your question if the claim is not considered closed even if you consider the obligation towards the beneficiary to be settled, the corresponding amounts of provisions should be reported in Gross RBNS.