Question ID: 793
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Template: S.06.02
Status: Final
Date of submission: 22 Sep 2016
Question
I have a question for you about the template S.30.04.01, more precisely about the column "C0300 : Code collateral provider (if applicable)".
On the filing_rules document, the values requested are:
-LEI/{Code}
-None
I can understand why the insurance company does not have to set an internal code for the collateral provider, but the column C0300 is a typed dimension, so it may be an issue (with the unique key of the table) if there is at least two collateral provider without a code LEI, we will end up with 2 lines with the value 'None' (and it won't be possible to establish a link between the collateral provider and the participation in this case).
Consequently it may be a good thing to update this template by:
Option 1: Allowing the use of internal code (as for the broker or the reinsurer)
Option 2: Setting an external code (as you did for the S.06.02 and the S.23.04 ).
Could you give me your position on this subject please?
EIOPA answer
Code collateral provider (if applicable)' is modelled in column C0300 of S.30.04 template as a typed dimension and 'None' must be reported when there is no LEI code for such collateral provider. However there can be number of collateral providers with different names ('Collateral provider name (if applicable)', column C0320) without LEI code. As a result it would not be possible to report it as typed dimension used for all of them in column C0300 would be 'None'.
As a consequence C0140 would not be sufficient natural key as well. To overcome the issue pointed out in the question, when a collateral provider does not have LEI, the "None" option with an alphanumeric unique code need to be reported. The technical details for reporting these elements with the EIOPA XBRL taxonomy can be found in the EIOPA XBRL list of known issues and/or filing rules.