We have some questions we think clarification would be helpful on E.04.01 (and the relationship with S.29.02): 1. There is some doubt with E.04.01 for non-life business, where investment income and expenses are allocated to technical provisions. The ECB instructions (and Q&A#2683) imply that such amounts (which are included in S.29.02) SHOULD be included in E.04.01 (otherwise the relationship between S.29.02 and E.04.01 wouldn't hold for non-life business), is that correct. Further, if that is so, then we assume they should be included in ER0050 (as Q&A#2940 confirmed that all other rows are for life business only).

In respect of the same article, how should the insurance/reinsurance undertaking document that an entity (bank) its compliant with Directive 2013/36/EU and Regulation (EU) No 575/2013 and can apply 100% solvency ratio and a PD of 0.5%?

In respect of Article 199, point 7, why would it be reasonable, that two banks that are both complying with Directive 2013/36/EU and Regulation (EU) No 575/2013, and one is rated and one is not, the one that is rated 4 based on its rating gets a PD of 1.2% and the one that its not rated gets assigned a PD of 0.5%? Can it be that the Article 199, point 7 penalizes the bank that has a rating compared to the one that does not?

We appreciate that Q&A 1848 states that plast should not be zero. However, we want to confirm if the plast inputs should be a full 12 months of earned premium or if plast should be consistent with the level of unexpired premium (i.e. if at the valuation date there are bound policies with the equivalent of two months of premium to be earned in the following12 months, then plast should be consistent and include two months of premium based on the prior year rates.)? In this scenario where the unexpired premium is small relative to a full year of premium, including a full year of premium exposure within the Plast input would not reflect the economic risk associated with the unexpired premium

In template S.04.03 underwriting entities should be reported. What exactly is the underwriting entity, can you provide a definition?

We have a question regarding Template S.14.03 item C00120 Amount of Claims Paid [Amount of claims paid, for the relevant product Identification, for claims that have been settled with payment during the reporting year]. Is this metric defined in the same way as in QRT 14.02? If yes, it this should be included in the description („This shall not include changes in provisions for claims that have not yet been paid and exclude claims management expenses and the movement in provisions in claims management expenses“). If it is not the same as in QRT 14.02 it should be specified.

We noticed some xbrl metric inconsistency in some reports. in S.37.02.04 and S.37.03.04 we can see for the column C0040 it is a percentage and define as Pure type but the metric mi2892 which is amount. In the report S.14.03.01, column C0110, C0130, mi2666 and mi2667 their labels are integer but datatype is monetary. Can you please clarify?

Template S.37.01.04 includes C0250 Insurance Policies. The following must be entered in this field in accordance with the Annex III - S.37.01.: The total amount of the exposure in the insurance policies (liability limit or sum insured depending which one represents the maximum possible exposure). But which specific insurance policies are meant here? Does this mean reinsurance that is not yet recoverable? Does this include other contracts, for example for insuring buildings with a third party?

I have a question in relation to the approach to be taken for the underwriting risk at year end. In this example, the insurer (a captive) has a year end of 31 December and a policy renewal date of 1 January. In the situation where the programme structure is changing (i.e. increase in risk) should the year end SCR calculation be based upon the next 12 months (i.e. new programme)? Or the existing programme, because the calculation date is 31/12 which is still technically in the prior year. We have had differing views from auditors on this point.