EIOPA · 131
131
- Regulation
- Guidelines on submission of information to NCAs (Preparatory phase)
- Article
- 35
- Submitted
- 2015-01-27
- Answered
- 2019-10-31
Question
In relation to QRT S.32.01.g, I have encountered myself with the following question: In QRTs S.06.02 and S.08.01 a company has to identify if subordinated debt is a participation or not (I understand subordinated debt corresponds to CIC category 28). Nevertheless, in QRT S.32.01, and in particular in cell M1, EIOPA doesn't mention the subordinated debt as a participation that has to be reported. Can you clarify if subordinated debt has to be identified as a participation for this QRT in general? If yes, cell M1 should include it, correct?
Answer
In fact there was a mistake in template S.06.02. Subordinated debt cannot be classified as participation. The LOG of this template was amended for the public consultation of the Technical Standard. However, please note that in the template Participations (not included in preparatory phase) information on whether the undertaking holds subordinated debt of any participation will be required.
Template S.32.01 is correct.
This Q&A is published by European Insurance and Occupational Pensions Authority and is non-binding. It does not constitute legal advice. Updated weekly from official ESA sources.
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