Skip to main content
European Insurance and Occupational Pensions Authority

814

Q&A

Question ID: 814

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

Article: 35

Status: Final

Date of submission: 19 Oct 2016

Question

1)    Where there are both assets and liabilities with the same counterparty, are we supposed to show the net position grouped as a single entry?

2)    In the C0050 closed list for option “5-liabilities insurance", does this include Life Technical Provisions?  (Our assumption is no as it is not meaningful or practical to attempt to split Life Technical Provisions as concentrations.)  If so, what form of concentration within Life Technical Provisions would need to be reported, e.g.:
a.    Individual contract, i.e. customer
b.    Geographical;
c.    Line of business or
d.    By risk driver (for example mortality)?

3)    In the C0050 closed list for option “8 – liabilities – others” what counterparties are EIOPA expecting to be included here? Does this need to include accounting liabilities on the balance sheet such as accruals and creditors?

4)    Also in the C0050 closed list what is the difference between “6-liaiblities-loans” and “7-liaiblities-debts”? Surely loans are debts?  What does EIOPA expect in each?

5)    Where reinsurance and derivative counterparties have posted collateral (and therefore the exposures to those derivatives are reported net of collateral) are we also supposed to “look through” the collateral accounts?  We assume not as the exposure to individual names held within a collateral account is somewhat indirect and also it would not be practical to do so.

6)    The template requires reporting of significant risk concentrations between entities in the scope of group supervision and third parties. Does this mean we are required to look through unregulated participations (other than insurance undertakings, ancillary service undertakings and insurance holding companies) to ascertain external counterparty information? For example this information is not provided on the assets QRT as participations are required to be reported in one line.

EIOPA answer

1) No, if there is more than one type of exposure per counterparty, separate entries have to be reported in separate lines, identifying the different nature of exposure, and  identifying the same counterparty (C0010/C0020).

2) Any liability related to insurance should be reported as “5”. However we do not understand how life TP could be an exposure to a counterparty, unless the counterparty is a natural person and the size of contracts associated to that natural person qualifies as a risk concentration, in which case option “5” should be chosen.

3) Any other liabilities, other than technical provision should be considered in this option.

4) In fact loans are a specific type of debt. Option ‘6’ should identify the loan and option ‘7’ should identify debts, other than loans

5) Not sure what is meant by look-through, but collaterals received should also be considered to the calculation of the risk exposure of its counterparty (as said in Instructions “Derivatives and collaterals are also to be included as well as exposures to sovereign counterparties.”).

6) The exposures of all entities reported in S.32.01 as within the scope of the group should be included in S.37.01