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Annex II to the Final Draft Report briefly mentions the “waterfall” example: A invests in B (e.g. purchases shares), B in C and C in D, where B and C are unregulated units of the conglomerate. This transaction shall be taken into account as specified. => In my view, A would not have to report a transaction (since investment does not meet a liability, see above), B and C would not have to act as they are not supervised, only D would have to report, as a supervised entity and through the sale of shares, funds flow, namely transaction A => D. Is this view correct?

In the draft ITS on the reporting of intra-group transactions and risk concentration, in the section “Current requirements as regards the reporting of information on risk concentration” (starting on page 9) it is proposed to report also the indirect exposures of a credit institution or investment firm belonging to a financial conglomerate (page 11). Here, indirect exposures are defined by the application of the substitution approach in Article 403 of Regulation (EU) No 575/2013, i.e. under the regulation for credit institutions and investment firms. Question: Do exposures of insurance companies belonging to a financial conglomerate therefore not fall under this new reporting requirement?

For the purpose of completing the reporting of significant risk concentration under Commission Implementing Regulation (EU) 2022/2454:

Question A: for the completion of templates FC.07 and FC.08 related to concentration, how should non-significant concentration be considered?

For the completion of template “FC.06 Risk Concentration - Exposure by counterparties”, could you clarify which methodology shall be used for determining the value of exposure to be reported, in particular for repo / reverse repo and derivatives?

Could you clarify in which case it shall be considered that a transaction is shifting risk exposures between entities outside the financial conglomerate (but where ultimately the risk exposure is brought back or stays within the financial conglomerate)? Shall transactions with non-consolidated SPV be considered as such indirect intragroup transactions to be reported or be considered as shifting risk outside the financial conglomerate and therefore are not required to be reported?

Following the changes to the ITS, we have identified a potential issue with the taxonomy validations between S17 and S19. In the new ITS it states that for the Undiscounted Best Estimate Triangles, the values should be reported "net of salvage and subrogation and excluding any expenses, as well as any future premiums."

According to Article 2 (15) of the PEPP Regulation an investment firm which manufacture PEPP products are allowed to distribute PEPP products it manufactures. We assume this includes distribution by tied agents of an investment firm whether in Home Member state or in Host Member state and such distribution is for the purpose of this question not considered 3rd party distribution. As per the PEPP Regulation Article 2 (16), 3rd party distributor can be: (i) financial undertaking as referred to in Article 6(1) authorised to distribute PEPPs not manufactured by it, (ii) an investment firm providing investment advice, or (iii) an insurance intermediary as defined in point (3) of Article 2(1) of IDD Directive.

According to "EIOPA_FICOD_DPM_Annotated_Templates_2.8.1_Hotfix.xlsx" in the template FC.07.01.36.02 in FC0040 the sector has to be filled with the hierarchy "NC – 1 from s2c_dim:NC". In this hierarchy several entries starting with “K” are marked as “false” in the column "Usable" in "EIOPA_DPM_Dictionary_2.8.1_Hotfix.xlsx". In “EIOPA_FinancialConglomerates_Technical_Logs_2.8.1_Hotfix.pdf” it is stated in section "8. FC.07.01 - RISK CONCENTRATION - EXPOSURE BY CURRENCY, SECTOR, COUNTRY": The ‘sector’ should present the split between the following sectors: a) public sector b) financial sector c) corporate sector divided by the NACE code

Regarding art. 11 (5) Business Impact Analysis (BIA). We would like to know if the Joint Committee are planning on publishing a BIA template?