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European Insurance and Occupational Pensions Authority

897

Q&A

Question ID: 897

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

Article: 35

Template: S.21.01

Status: Final

Date of submission: 30 May 2017

Question

I am now confused by the answers to Q93 and Q137 about how the S.21.01 should be completed. A93 said that one should use "the sum of the claims paid during the financial year plus RBNS at the end of the financial year". A137 gave an example : if paids in 2016 were £20 and RBNS at 31/12/16, the incurred is £120. In 2017, the paid is £10 and the RBNS at 31/12/17 is now £80 so the incurred for 2017 is £90.

What the example hasn't made clear is whether or not the £10 in 2017 is an additional payment (thus making the cumulative payments £30); or if the cumulative payments are now £10 (after having processed a refund of £10 in 2017). Although A137 does say that "the claim in question has been revised down by £10 in 2017" so it sounds like the former.

If it is the former - that one only looks at the claims in 2017 when completing the 2017 S.21.01 - then the incurred value - £80 - is conceptually meaningless. It is neither the cumulative incurred value on the claim (which must be £20 + £10 + £80 = £110) nor is it the incurred in the financial year 2017 (£10 -£100 +£80 = £-10).

Personally I would have thought you wanted the template to show cumulative paids plus the latest RBNS.

Furthermore, I note the comment to A80 that there can never be a negative incurred claim value. But if we are to only look at paid claims in the reporting year we could. Take the following scenario. In 2016 : paids £20 and RBNS £100. Incurred £120. In 2017 paids (ie purely paid in 2017) £10, RBNS £80. Incurred on the basis of A93) is £90. In 2018, the claim was closed at a further cost of £15 and the insurer also made salvage recoveries of £30. RBNS nil. Incurred is (+15-30+0) -£15. Having salvage and subrogation in a different reporting year to the paids is very common.

On a cumultaive basis, I agree the the incurred can never be less than nil (here 90+10+15-30). And I think the answer to Q80 was adopting this approach. A137 seems to be a change in approach.

EIOPA answer

In fact the answers to the questions regarding template S.21.01 have not been clear enough. The reason for that was the lack of clarity in the Instructions combined with the fact that traditionally this type of information is analised with accumulated amounts as you highlight. 

It is now possible to clarify that the amounts to be reported in template S.21.01 should be the "accumulated claims incurred at the end of the reporting year", meaning sum of the cumulative gross claims paid (over the years) to the reporting date (ie the cumulative gross paid claims) and gross reported but not settled claims (RBNS) at the reporting date on a case by case basis for each and every single claim, open or closed, which belongs to a specific accident year ("AY")/underwriting year ("UWY") (AY/UWY).

Historical data, starting from the first time application of Solvency II, is required for claims paid (in line with the information needed for template S.19.01.
EIOPA will put forward a corresponding proposal of clarification in the next revision of the ITS. In the meantime, undertakings can choose to comply with this interpretation in time for the annual 2016 Solvency II submissions. 

All answers to related questions will be revised to reflect this clarification.