1552

S.29.01.R0120 and R0130 do not reflect the same concept even if for some undertakings it could be the same value.S.29.01.R0120 should reflect the variation of the basic own funds items reported in S.29.01. i.e. excluding "Own funds from the financial statements that should not be represented by the reconciliation reserve and do not meet the criteria to be classified as Solvency II own funds" and "Deductions for participations in financial and credit institutions". This amount includes the variation of subordinated liabilities. S.29.01.R0130 should reflect the variation of excess of assets and liabilities. This amount should also be considered before deductions for Participations in financial and credit institutions, meaning that the difference between the two amounts refer to "Own funds from the financial statements that should not be represented by the reconciliation reserve and do not meet the criteria to be classified as Solvency II own funds" which is not included in R0120 and should be reflected in R0130 and also to the fact that the variation of the subordinated liabilities is not considered in R0130 as they are deducted from the assets.