EIOPA · 3131
Reporting Templates
- Regulation
- (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
- Article
- ANNEX VI Definitions of the CIC Table
- Topic
- Reporting Templates
- Submitted
- 2024-07-25
- Answered
- 2024-10-17
Question
We have an interpretation doubt about CIC 84 and CIC 88 classification. As per our classification meaning, all the mortgages should be reported under CIC 84, despite they are made to natural or juridical persons. Otherwise, if we report under CIC 88 all loans made to natural persons, we include both mortgage loans and policy loans under the same class. But those instruments have different characteristics and risk factors. Our interpretation is correct? We should report mortgage loans always under CIC 84?
Background
CIC84 "Mortgages and loans"=Mortgages and loans made with collateral in the form of real estate. CIC88" Loans to other natural persons"=Loans made to other natural persons. This class shall prevail over the ones above.
Answer
EIOPA is aware of the issue raised and is planning to look at it in the next ITS amendments. Until then the instructions shall be followed and as such when relevant report mortgages as CIC 88 which prevails over other CICs.
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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