Considering the new requirments on total SII amount calculation, where a new approach has been introduced for some CIC categories which total SII amount was previously not subject to calculation but treated as direct input, an issue may arise when assets labelled with CIC codes that require some aggregation are involved (except CIC code 71 and 95) and are held by the undertaking in both index/unit linked portfolios and traditional business portfolios.

We seek confirmation that, with reference to those assets that need to be aggregated for reporting purposes, the index/unit link flag can be deemed as a (shadow) duplication element on the table "Information on assets".

Example given:

Please consider loans on policies to other indivduals:

1. Unit link portfolio: unit percentage of par amount S2 price = 99, par amount = 100
1. Unit link portfolio: unit percentage of par amount S2 price = 101, par amount = 100

In order to retrive the correct amount on table "information on position held" two different lines using two different prices will have to be reported also on table "information on assets". Please confirm.