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European Insurance and Occupational Pensions Authority

765

Q&A

Question ID: 765

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

Article: 35

Template: SR.02.01

Status: Final

Date of submission: 05 Aug 2016

Question

Remaining Part:
I was working on the basis that Remaining Part captures any business within the entity which does not fall under any Ring-fenced fund or Matching Adjustment portfolio.  So, for a simple case where an entity has 1 RFF and 1 MAP (with no overlap), the sum of RFF + MAP + Remaining Part will reconcile to the Total Entity (ignoring any measurement differences).  So, for the Balance Sheet SR.02.01 QRT, which is disclosed for each material RFF and the Remaining Part, I had assumed that Remaining Part here would capture any business not in the material RFF.
However, recent feedback from the EIOPA DPM and XBRL team implies that this is not the case – instead this feedback implies that the Remaining Part does not contain any Matching Adjustment Portfolio business.
Please can you confirm the definition of Remaining Part for the SR QRTs?

Sub-fund reporting:
I was working on the assumption that sub-fund reporting is only required for the SR.25, SR.26 and SR.27 QRTs.  This is on the basis that only the EIOPA Log instructions for these QRTs explicitly mention any sub-fund reporting requirements.

However, recent feedback from the EIOPA DPM and XBRL team implies that this is not the case – instead this feedback implies that sub-fund reporting is required for all SR QRTs where RFF/MAP reporting is required (e.g. sub-fund reporting is required for each of the SR.01, SR.02, SR.12. SR.17, SR.25, SR.26 and SR.27 QRTs).
Please can you confirm for which SR QRTs additional sub-fund reporting is required?
In addition, for these additional sub-fund requirements, can you please confirm that all the sub-funds (i.e. “son” funds) and the “remaining part of the sub-fund” have to be reported separately, but that the material “mother fund” does not need to be reported?

EIOPA answer

The feedback provided by DPM and XBRL team is correct. The definition of the remaining part needs to be consistent across templates, regardless if the information on the MAP is requested or not. In the specific case of the balance-sheet, a decision was taken not to request the balance-sheet by MAP, however this does not impact the definition of remaining part. In other cases such as the S.26 templates, where information is requested by RFF and by MAP, the remaining part would need to exclude the MAP business.
In sum “remaining part of the business” is the business which is not material RFF or MAP. The definition of remaining part is the same across templates.
In reality your assumption that the sum of material RFF + MAP + Remaining Part will reconcile to the Total Entity is correct.
Sub-fund reporting is required where a RFF/MAP includes a MAP/RFF embedded. Therefore the reporting requirements applicable to RFF and MAP apply to each sub-fund, according to its nature (RFF or MAP). This means that we confirm that all templates required to be reported under article 18 or 34 should be reported for all sub-funds. In cases of sub-funds, all “son” funds have to be reported, including the “remaining part of the fund”. The “mother” fund does not need to be reported in addition.

Please note that answers by EIOPA DPM and XBRL team are supported by EIOPA business team whenever the question relates to business clarifications.