EIOPA · 2522

Reporting Templates

Regulation
(EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article
Article 35 of SII Directive
Topic
Reporting Templates
Submitted
2022-11-04
Answered
2023-05-04

Question

Regarding the EIOPA's answer to the question Nr. 2282 on the classification of fixed to floater bonds with a call option, could you please confirm which of the below features qualifies these instruments as a structured products (CIC 5x): a)    embedded option (call, put) regardless of coupon setup b)    coupon type change from fix to float (or the other way round)  We’d like to point out that for these instruments the interest periods and the final repayment amounts are predefined for all periods, the period sequence and the call date is also predefined. This means that there is no event that would be still uncertain at the time when the security is issued.  Summarizing, fix to floater instruments are traditional bonds in our view, according to Q&A nr.562 callable bonds without any structured feature besides the early redemption option should be classified as bonds. Therefore, could you please confirm the correct classification of the fix to floater instruments with a call option.

Background

According to our knowledge, fixed to floater instruments are traditional bonds; according to EIOPA's guidelines the call option itself also does not constitute a derivative component, therefore we'd like to re-confirm on the correctness of classification provided in answer to Q&A 2282.

Answer

The CIC category for fixed or floater bonds depend on the individual features of the asset. Simple additional features (e. g. 'fix to float' or floor/ceiling) can also be considered as CIC 2. FRNs with more complex additional features should be categorized as CIC 5. The decision if a instruments should be considered as having “derivative component" should be taken from a risk perspective. ​

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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