Reporting Templates

Can EIOPA please clarify some commonly held uncertainties on S.27.01 regards reporting the results of aggregate reinsurance covers. For example, in the windstorm section columns C0100 and C0110. The context being that C0120 must be C0090-C0100+C0110 as per BV271 (Blocking validation). This is problematic because reinsurance recoverables are not actually against that gross (disaggregated) loss in C0090; C0090 is before (higher level) diversification benefits (e.g. with non-EEA windstorm losses) but the risk mitigation must be applied post such diversification (if the reinsurance relates to an aggregate cover an a higher level of losses eg global) being applied (and the gross loss at the region level thus being updated to a different, lower amount, that takes into account the diversification benefit between EEA and non-EEA). Hence we have for reporting a gross and risk mitigation on two different bases and the resulting net SCR (C0120) is incorrect (unless we manipulate, presumably C0100 and C0110, in some way). For example: Assume following gross (disaggregated, within their respective regions) losses - Ireland gross SCR (C0090 R0480) of 1000 - US gross SCR (C0090 R0790) of 1000 With, for simplicity, only one reinsurance cover being an aggregate global cover of 1500 XL 500 and no resinstatement premiums. As per GLs on application of RI program for CAT module, the total WS SCR (applying diversification) is calculated as 1414 (QRT(1000^2+1000^2). The XL cover is applied against this loss and hence we have retained (global, net) SCR of 500 and recoverables of 914. At this stage we seek guidance on how to report this: - should we disaggregate the reinsurance recoverables of 914 to Ireland and US rows in S.27.01 ie C0090 R0480 of 457 and C0090 R0790 of 457 (but this gives an incorrect C0120 amount for both rows as the net SCR for both is not 543); or - should we disaggregate the net SCR of 500 to Ireland and US rows in S.27.01 ie C0120 R0480 of 250 and C0120 R0790 of 250 (and then "back-out" from here the reinsurance recoverables in C0100 as 750 in both rows) Obviously the latter option respects BV271 and allows the total net SCR to be calculated from the individual S.27.01 (region) row net SCR values (although see next question for reporting net total diversification amount) - but it is incredibly complicated to do, particularly where we have more complicated reinsurance programmes with different aggregate cover levels eg regional and then global and recoverables and reinstatements. Further, could EIOPA please extend their answer the above question to explain how the subsequent total diversification of net SCR should be reported (eg for windstorm the data point C0120 R0810). We are very confused by this data point because in pretty much any conceivable approach the individual net SCR amounts reported already take into account diversification via the disaggregation applied in generating the gross losses - so conceptually reporting diversification benefits of net SCRs is seemingly irrelevant. Public Solvency II Solutions C0090-C0120 should be after diversification effects, including R0600 which will be amended accordingly. BV271 will be deactivated to report the right amount in C0120.