Disclosure Templates

Thanks for the response to question #2599. We want to double-check this response as it was not in line with our expectations. So far as we understand, the S.04.05.01 threshold is on a line of business and underwriting entity level because information is first split by line of business Z0010 and underwriting entity Z0020 and then information is provided by country breakdown, up to 95%. We also assume that if a country is reported in S.04.05.21 then the amounts for that country should represent 100% of the amount for that country. It was on these assumptions that our question was raised; because it appears that if country A was (overall) part of the (S.04.05.21) top 5 (other than home country) but country A was part of (S.04.05.01) "other countries" for one or more lines of business and underwriting entity combinations then we would not be able to complete S.04.05.21 from the information available. If EIOPA could confirm that the 95% threshold in S.04.05.01 was at the overall (total business) level i.e. calculate GWP breakdown by country (regardless of line of business and underwriting entity) and determine which countries should be included to reach 95% , then ensuring those countries are always included explicitly (and not contained in other countries) for every underwriting entity and line of business combination. In that case the answer to Q&A #2599 makes sense but we would raise the point that that would make the application of the threshold in S.04.05.21 potentially onerous and not necessarily in line with how the business is managed (i.e. at underwriting entity and/or line of business level)