EIOPA · 1767
1767
- Regulation
- (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
- Article
- 35
- Submitted
- 2019-04-26
- Answered
- 2019-10-15
Question
Regarding the cell C0010/R0030 'Valuation movements on financial liabilities and subordinated liabilities' on template S.29.02, it appears to include all movements on subordinated liabilities. This cell is part of the 'Variations due to investments and financial liabilities' as reported in C0030/R0190 on S.29.01, which means that, by extension, part of the subordinated liabilities reported on S.29.02 may end up included in the 'Excess of assets over liabilities' in cell C0030/R0130.
However, EoAoL serves a basis for the calculation of the 'Variation of Reconciliation Reserve' on C0030/R0180. Following the reasoning, part of the subordinated liabilities may still be included on C0030/R0180, meaning these should also be included in cell C0030/R0080 of the same template S.29.01. Since C0030/R0090 is dedicated to 'Subordinated liabilities' as well, do you think there is a chance of double counting variation movements for subordinated liabilities on table 1 of template S.29.01 (a small fraction of these movements in C0030/R0080, and the bulk of it in C0030/R0090)?
Answer
In "EIOPA Explanatory notes on reporting templates - Variation Analysis templates" 1.16 the cell C0030/R0190 on template S.29.01 corresponds to the sum of S.29.02.R0010, S.29.02.R0030, S.29.02.R0040 minus S.29.02.R0050 and the subordinated liabilities are taken into account. At the same time, in SolvencyII Validations the cell C0030/R0190 on template S.29.01 is not equalt to cell C0010/R0060 on template S.29.02, which is Variation in Excess of Assets over Liabilities explained by Investments and financial liabilities management.
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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