Question ID: 773
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Template: S.06.01
Status: Final
Date of submission: 30 Aug 2016
Question
As far as we understand the ITS published by the EIOPA it seems that QRT S.06.01 may only be submitted annually when the undertakings are exempted from annual submission of QRT S.06.02 or S.08.01
EXTRACT FROM THE ITS (1)
2.15. Investments summary – S.06.01:
a) Stakeholders questioned the need for this template.
b) EIOPA clarified that this template is only due by undertakings/groups exempted from the annual submission of information in templates S.06.02 or S.08.01 in accordance with Article 35 (7) of Directive 2009/138/EC. EIOPA believes that by guaranteeing a minimum set of information for supervisors it is more probable that exemptions are given. The template has not changed
From my understanding In case an undertaking submits QRT S.06.02 / S.08.01 on a quarterly basis it should be exempted from annual submission of such QRT in regards of option 7 - Not due as no material changes since quarterly submission of the Annex II and III, and so on will have to submit QRT S.06.01 in the annual submission instead.
EXTRACT FROM THE ITS (2)
C0010/R0140
S.06.02 - List of assets
One of the options in the following closed list shall be used:
1 - Reported
6 - Exempted under Article 254(2)
7 - Not due as no material changes since quarterly submission
0 - Not reported other reason (in this case special justification is needed
C0010/R0170
S.08.01 - Open derivatives
One of the options in the following closed list shall be used:
1 - Reported
2 - Not reported as no derivative transactions
6 - Exempted under Article 254(2)
7 - Not due as no material changes since quarterly submission
0 - Not reported other reason (in this case special justification is needed).
I do not understand why in the Annex II and III for QRT S.01.01, EIOPA has defined the following “Option : 4 - Not due as S.06.02 reported quarterly” on row R0130.
MY QUESTION : In which case an undertaking submitting QRT S.06.02 / Q.08.01 on a quarterly basis only may be exempted from reporting yearly the QRT S.06.01?
EXTRACT FROM THE ITS (3)
C0010/R0130 S.06.01 - Summary of Assets One of the options in the following closed list shall be used:
1 - Reported
4 - Not due as S.06.02 reported quarterly
5 - Not due as S.06.02 reported annually
0 - Not reported other reason (in this case special justification is needed
EIOPA answer
Template S.06.01 is only due when template S.06.02 or S.08.01 are exempted both quarterly and annually.
The following situations may occur:
o Option 4 should be chosen when templates were not exempted quarterly (4 quarters are submitted). Annual submission is only requested if material changes since quarterly submission have occurred. Template S.06.01 is not due as detailed information was already reported in S.06.02 and S.08.01 for Q4.;
o Option 5 should be chosen when templates are exempted quarterly but requested annually, or they were exempted quarterly but re-submitted annually as material changes since quarterly submission have occurred. Template S.06.01 is not due as detailed information is reported in S.06.02 and S.08.01 for annual submission;
o Option 1 should be chosen when templates are exempted both quarterly and annually. Template S.06.01 is due to guarantee minimum information on investments.