Question ID: FICOD028 - 3385
Regulation Reference: (EU) 2022/2454 - ITS with regard to supervisory reporting of risk concentrations and intra-group transactions (FICOD
Topic: Reporting templates on risk concentrations and intra-group transactions for conglomerates (FICOD)
Article: Annex II
Template: FC.01
Status: Final
Date of submission: 18 Jul 2025
Question
In which category must be reported investments in funds (FC01/FC0120/Instrument)?
1 - bonds/debt - collateralised
2 - bonds/debt - uncollateralised
3 - equity type - shares/participations
4 - equity type - others
5 - other asset transfer - properties
6 - other asset transfer - others
EIOPA answer
The category to be selected for filling FC0120 of FC.01 depends on whether the investment fund is considered as an undertaking of the financial conglomerate (direct IGT) or not (indirect IGT) and, in the latter case, on the nature of the underlying exposure that the investment funds held in the other undertakings of the concerned financial conglomerate :
Where the investment fund is not an undertaking of the financial conglomerate, which is assumed to be the vast majority of cases and as provided by EIOPA Q&A 3064, a look through approach shall be applied and only the two ultimate counterparties of the transaction are expected to be reported. As a result, reporting and category shall be based on the nature of the exposure that is held indirectly through the investment fund, i.e. if an insurance undertaking of the financial conglomerate holds 5% of an investment fund which holds in turn 100 of debt securities issued by a credit institution of that financial conglomerate : that transaction is an indirect intragroup transaction but as the investment fund is a third party, only the transaction between entities that are part of the financial conglomerates, i.e. the insurance undertaking and the credit institution, shall be reported (the intermediary step have to be mentioned in comment) and, for this example, the category “2 - bonds/debt – uncollateralised” shall be used, i.e. considering the nature of the underlying exposure. In accordance with article 11(2) of Directive 2002/87/EC, the coordinator may allow insurance led financial conglomerates to not report such indirect intragroup transactions if the information is already provided through other sectoral reporting;
- Where the investment fund is considered itself as an undertaking of FICO (e.g. in the case for instance where such investment funds is considered as “a financial institution or an ancillary services undertaking” and consolidated in the applicable sectoral perimeter) : the holding of the share by another undertaking of the financial conglomerate is by itself a “direct” intragroup transaction and the category “6 - other asset transfer – others” shall be used.