Question ID: 828
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Template: S.23.03
Status: Final
Date of submission: 19 Oct 2016
Question
We are looking at the currency translation at group reporting for S23.03. This templates reports at a opening and closing balance with movements between. It is not clear how the effect for FX translation over the open to close period shall be reported where there has been currency translation of specific solo entities to the group currency. Please consider the example below:
S.23.03
This template details the “flows” or “movements” from Opening Balance to Closing Balance of a selection of Own Funds accounts. At Solo level, no problems. But at a translated level, how do we report the Foreign Exchange effect on the flows?
So for example:
Beginning Exchange Rate: 4
Average Exchange Rate: 5
Ending Exchange Rate: 6
Un-translated:
Opening Balance: 100
Movements: 50
Closing Balance: 150
Translated:
Opening Balance: 400 (100 * 4)
Movements: 250 (50 * 5)
Closing Balance: 900 (150 * 6)
It doesn’t balance (i.e. Opening + Movements ¹ Closing Balance). Does EIOPA expect it to balance?
From an accounting perspective there is a Foreign Exchange Effect movement:
(Opening Balance * Closing Rate) – (Opening Balance * Opening Rate) + (Movements * Closing Rate) – (Movements * Average Rate)
100 * 6 -100* 4 + 50 * 6 – 50 * 5 = 600 – 400 + 300 – 250 = 250
Translated:
Opening Balance: 400 (100 * 4)
Movements: 250 (50 * 5)
FX Effect 250
Closing Balance: 900 (150 * 6)
Now it balances.
But where do we report the FX Effect? There is nowhere in the template to include this entry
The only way we can balance without an FX entry is to translate Opening Balance and Movements at Closing Rate. But if we do that, then the Opening Balance next year will NOT equal the Closing Balance of this year.
EIOPA answer
All amounts should be reported using the closing exchange rate. It is true that in this case the opening Balance of a year will not be equal to the closing Balance of the previous year, but this should not matter. The purpose of the template is not to match with figures reported in previous years but to understand the movements over the year.