Question ID: 2407
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Topic: Reporting Templates
Article: 35 of SII Directive
Template: S.11.01
Status: Rejected
Date of submission: 22 Mar 2022
Question
The Regulation states that this template should be completed on the basis of " item–by–item list of off–balance sheet assets held as collateral for covering balance sheet assets held directly by the undertaking". In a prior Q&A (#933) the EIOPA response to the query refers to Reinsurance business held as collateral to be reported as "0" Other investments. Can you please clarify whether collateral held for Reinsurance receivables which are reported in the Balance Sheet, and also via S31.01, should be reported in S11.01 or whether S11.01 is strictly off-balance sheet only.
Background of the question
To date we have not reported S11.01 on the basis that it is off-balance sheet, however the CBI referred us to Q&A#933 and interpreted this to mean we should report S11.01 for collateral on reinsurance receivables even if they are on the Balance Sheet.