Question ID: 1151
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Template: S.04.01
Status: Final
Date of submission: 13 Jun 2017
Question
In the ITS Reporting Log for S.04.01, 3 formulas are specified:
C0040 = Sum of C0080 for all branches
C0050 = Sum of C0090 for all branches
C0060 = Sum of C0100 for all branches
And in the List of validations in the taxonomy:
BV201: R0020 / {c0020}+{c0050}={c0060}
Can you please clarify how to satisfy these formulas for business written by an EEA branch with a location of risk outside the EEA.
The ITS reporting log states that for Non EEA business:
” The localisation of business by country shall depend on where the business is underwritten, meaning that the business performed by a branch under FPS shall be reported under the country where the branch is established.”
In the example where €100 of business is written by a UK Branch with a location of risk of Australia, C0090 for GB will be €100. Based on the formula above C0050 is also €100 (C0050 = Sum of C0090 for all branches) and C0060 is also €100 (BV201: R0020 / {c0020}+{c0050}={c0060}). For business with an EEA location of risk column C0100 would be populated with €100 in the country where the risk resides. However C0100 only applies to EEA countries (as per the taxonomy dimension GA_13 applied to this field), and as the location of risk is Australia, C0100 is 0 for this transaction. This means that the formula C0060 = Sum of C0100 for all branches cannot be satisfied. C0060 will be greater than the sum of C0100 by the value of non EEA risk business.
As such we believe that the assertion “C0060 = Sum of C0100 for all branches” only applies to business with a location of risk inside the EEA.
EIOPA answer
The instructions "The localisation of business by country shall depend on where the business is underwritten, meaning that the business performed by a branch under FPS shall be reported under the country where the branch is established" apply to both EEA and non-EEA branches. This template is not to be reported considering the localisation of risk but where the risk is underwritten.
C0100 only applies to EEA countries as the concept of FPS is not applicable to non-EEA Members. Please see also Q&A 935.
Regarding your specific example please note that the business underwritten by the UK Branch should be reported under C0080 (and summed under C0040). The criteria of this template is where the business is underwritten.
Please note that BV201 has been de-activated on 21/04 and will be amended as follows: {c0020}+{c0050}={c0060}+{c0030}