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European Insurance and Occupational Pensions Authority

763

Q&A

Question ID: 763

Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities

Article: 35

Template: S.36.03

Status: Final

Date of submission: 05 Aug 2016

Question

We have a question in relation to S.36.03 QRT (IGT - Internal Reinsurance) - C0090 - "Validity Period (expiry date".
The LOG states that the item is not to reported if a contract is continuous and ends by one of the parties giving notice. For this purpose, if a treaty starts at 01.01.20XX and ends at 31.12.20XX but is automatically renewed every year (the reinsurer remains responsible until the natural expiration or commutation of the treaty), would it be considered to be continuous? The structure implies that there is an expiry data in the treaty, but in spite of this, the expired treaties are continued due to the runoff obligation which indicates no explicit expiry date. In this case, figures would be reported as a total of the renewed treaties without an expiration date. Can EIOPA confirm this interpretation?

EIOPA answer

The interpretation is correct. In the cases where the contracts are automatically renewed the validity date should not be reported.
This specific template (S.36.03) aim the supervision of IGTs therefore the amount to be reported should be the amount related to 31.12.20xx (as reflected in the balance-sheet) not the renewed value at the 01.01.20xx+1.