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European Insurance and Occupational Pensions Authority

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3010

Questions are regards S.25.05 (note this QRT is not in the dropdown list available in the Q&A page). We find some doubt about if and how the SCR total and other key fields can be derived from other datapoints in this (and/or other) QRTs. 1. Is S.25.05 _C0100_R0200 = _C0010_R0040+SUM(_C0100_R0120,_C0100_R0160)? Our assumption is the C0010 R0040 is the diversified SCR (and takes into account LACDT and LACTP) and so all that is left to do is make the adjustment for RFF and R0160 and then we arrive at the actual SCR amount

3033

I am writing to seek clarification on a matter of significant importance raised in a letter published in March 2023 by John BERRIGAN, addressed to Ms Petra Hielkema Chair of EIOPA, Ms Verena Ross Chair of ESMA and Mr José Manuel Campa Chair of EBA (Letter from John Berrigan One off exercise - European Union (europa.eu)). The letter addressed the need for a one-off climate risk scenario analysis to assess, in cooperation with the ECB and the ESRB, the resilience of the European financial system.

3056

While performing a test upload for the 2.8.0 taxonomy, we constantly receive a formula assertion warning as below [BV1439];[(t: S.17.01.01.01, r: R0160, c: C0030) reported as {$v0} = sum((t: S.19.01.01.04, r: R0260, c: C0360, z: Z0001, filter: [s2c_dim:BL] = [s2c_LB:x52]) reported as {$v1})]; The item "Gross - Total" reported for Income protection insurance in S.17.01 should be equal to "Total" item reported for Year end (discounted data) reported in S.19.01. This applies for all LoB and for S.19.01.01.10 and S.19.01.01.16 even when S.17.01.01.01 items reconcile with the amount of S.19 Can you please elaborate further on the issue? Can this be solved or is a known error in the new taxonomy?

2977

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).

3046

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%?

3045

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?

3005

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

3017

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

2802

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.

3054

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?