In S.12.01, for Direct business, FGB R0240 and FDB R0250 are disclosed for WP business only (in C0020) – with a combined R0230 “Future guaranteed and discretionary benefits” disclosure for other lines of direct business (i.e. in C0030, C0060, C0090, C0160).  Direct business disclosures are straightforward, allowing disclosure of FGB and FDB for all direct business categories (either split across R0240-R0250 for WP or combined in R0230 for non-WP).

However, Reinsurance Accepted (RA) disclosures in C0100 for these rows are less clear.  C0100 does not allow R0230 disclosure, and only allows R0240-R0250 disclosure.  As R0240-R0250 for Direct business only captures C0020 (WP business), one might think that R0240-R0250 in C0100 also captures only WP business.  However, as C0100 has no C0230 disclosure, and as C0100 is a Total column which should capture all types of RA Life business, then it makes sense that R0240 / C0100 captures all types of Life RA business (e.g. WP, IL/UL and Other) not just WP.  If it only captured WP, then future guaranteed benefits on other RA business (such as annuity business) would be missing in R0240 / C0100 column.  This doesn’t make sense.

Can you confirm please that R0240 / C0100 in S.12.01 should capture all Life business (e.g. WP, IL/UL and Other) and not just WP?

Similarly, I am assuming that the C0100 disclosures for rows R0260, R0270 and R0280 also capture all lines of Life RA business.

Note that this “catch all” approach seems to contradict EIOPA response to Q4 in “Final report 14-055” (which implies that C0100/R0240-R0250 captures only WP business).