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European Insurance and Occupational Pensions Authority

957

Q&A

Question ID: 957

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

Article: 35

Template: S.08.01

Status: Final

Date of submission: 03 Feb 2017

Question

In the Q&A document 'Final Report 14-052_01_09_2016" there is differing advice on how to report FX forward positions in the S.08.02 template.  

Number 87 advises:
In a currency forward contract it is assumed that the two currencies involved are the reporting currency and a foreign currency. The foreign currency is identified in C0310 and the position in the contract is identified in C0130.

If it is a contract with two foreign currencies, it is more probable that it is a currency swap, in which case C0350 and C0360 should be used to identify both currencies.
However Number 111 advises:
In this case, and also in the case of currency forward contract involving the reporting currency the following should be reported:

- C0120 should identify the nominal amount

- C0310 should identify the currency of the nominal amount, currency being fixed

- C0330 should identify the currency and exchange rate  

For example, in a forward contract USD|GBP, 1 000 000 USD, exchange rate USD|GBP = 0,6959:

- C0120: 1000000

- C0310: USD

- C0330: GBP 0,6959

Please note that C0130 (buyer/seller) is not applicable to forwards

1) Which of these is correct?  
2) Is it correct to presume whichever treatment is correct for the S.08.02 template will also apply to the S.08.01 template?

3) a) If Number 87 is correct, in order to show the direction of the trade via the C0130 field we would need to be able to enter negative and positive values (as we have USD/GBP and GBP/USD forwards), is this currently permitted?  3) b) Also, if we had an fx forward with two foreign currencies, would we put one of the currencies in the Currency field C0310, and the second currency in C0360, leaving C0350 populated with the appropriate '1 - LEI' or '9 - None' entry that is relevant to the code that has been submitted?

4) Regarding 111 (if this is correct), should C0120 and C0310 always reflect the buy leg of the forward?  The example in 111 seems more logical and easier to implement than the response to 87.

EIOPA answer

Q&A 687 (before 111) is correct. The final part of Q&A 616 (before 87) is also correct.

As stated in Q&A 687 (before 111):
In the case of currency forward contract involving the reporting currency the following should be reported:
 - C0120 should identify the nominal amount
 - C0310 should identify the currency of the nominal amount, currency being fixed
 - C0330 should identify the currency and exchange rate

 For example, in a forward contract USD|GBP, 1 000 000 USD, exchange rate USD|GBP = 0,6959:
 - C0120: 1000000
 - C0310: USD
 - C0330: GBP 0,6959

Or, in a forward contract GBP|USD, 1 000 000 GBP, exchange rate GBP|USD = 0,6959:
 - C0120: 1000000
 - C0310: GBP
 - C0330: USD 1,4385

In addition, regarding your question 2), if it is a contract with two foreign currencies, it is more probable that it is a currency swap, in which case C0350 and C0360 should be used to identify both currencies (as stated in the final part of Q&A 616 (before 87).

However in the case of a forward with two foreign currencies, the same approach should be used. The currency of the notional amount in C0310 and the second currency in C0330 together with the currency exchange rate.

The treatment is applicable to both S.08.01 (C0370 and C0390) and S.08.02 (C0310 and C0330).
C0120 and C0310 should always reflect the notional amount and currency of the notional amount.