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The answer to Q&A#2630 is not 100% clear to us:"S.37 should include all type of exposures and is therefore not limited by information in S.06. However, when specific asset characteristics are not applicable (e.g. country of issuer is not applicable) to the assets following the assessment for S.06 this will also impact the tables under S.37 (e.g. table S.37.02.04.03 exposure by country will not reflect this asset but the asset still needs to be included in for example S.37.01.04.01, if significant)

Can EIOPA please clarify the requirements for amounts to be entered into the new rows R0800 and R0810 of S.23.01 group version. We believe that: R0800 should equal sum of R0520 + R0440, for columns C0010 through C0050 respectively R0810 should equal sum of R0520 + R0460, for columns C0010 through C0050 respectively

Could you please provide some context on some of the Validation Rules between QRTs S.09.01.01 and S.29.02.01, where these rules seem to contradict the ITS.

We have a question regarding reporting amounts for Proportional reinsurance accepted (items R0120, R0220, R0320 etc.) in the S.05.01 template. Are the instructions for Written / Earned premiums in the ITS 2023/894 valid not only for Direct business, but also for Proportional reinsurance accepted? The instructions say that „Written/earned premiums shall be reported as defined in Article 1(11) and (12) of Delegated Regulation (EU) 2015/35 regardless of whether a local GAAP or IFRS is used.

Insurer B has a 100% quota share reinsurance contract with Reinsurer C that includes a “pay as paid clause”. This clause specifies that Insurer B has no liability to the Original Insured A until Reinsurer C has paid the reinsurance claim to Insurer B. The original insurance contract between the...

In answer #2577 EIOPA stated that cash deposits that are recognized should also be reported in QRT S.03.01. and that government bonds pledged as collateral should also be reported in S.03.01. In former statements/answers EIOPA made counter instructions:

We have an additional question regarding the 2015-2450 Q&A No. 2225 and the change in validation for XT79 assets.

Through the Credit Support Annex, we have provided and received cash collateral and government bonds (counterparties are mainly financial institutions).

2 questions:

We would like to clarify a topic about Future discretionary benefits (FDB) and Future guaranteed benefits (FGB). According to the definition of FDB in the ITS (COMMISSION IMPLEMENTING REGULATION (EU) 2023/894) for S.12.01, we understand that the Line of Business (LoB) “Index-linked and unit-linked” (UL/IL) cannot have FDB. This would mean that all Future benefits should be entered in the column FGB in S.13.01 as there is no other option – even if the future benefits for UL/IL are not guaranteed.

Since taxonomy 2.8.0 there is a new field ‘Non-available own funds in the reconciliation reserve’ (C0841 or C0951) for both the solo level (table 10) and the group level (table 11). Could you please give examples of own funds components that you see under this category?

At which level should IPIDs be drafted (this is akin to asking what is meant by “product” since there should be 1 IPID per product)? Should the different coverage levels (gold, silver, platinum, ...) of optional and non-optional guarantees commercialized for a product be disclosed within the same IPID (approach 1 below) or should there be one IPID per level of coverage commercialized for each product (i.e. an IPID for the gold level of coverage of the product, another IPID for the silver level of coverage of the product, another one for the platinum level of coverage of the product) (approach 2 below)?