Question ID: 245
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Template: S.23.01
Status: Final
Date of submission: 06 Nov 2015
Question
The own funds report s.23.01 requires values for total eligible own funds to meet the SCR in cell B50, and total eligible own funds to meet the MCR in cell B51. The technical annex II states that these values should be equal.
This will not be true where a non EU insurance subsidiary is brought in to own funds. In that case both the eligible own funds to meet the MCR and the MCR itself are brought in on a local regulatory basis rather than a solvency II basis. As such the cells can not match.
EIOPA answer
The old cells B50 and B51 existed in the individual template only. The correspondent cells in the group template were B50A and B51A. This cells were to be reported reflecting the consolidated part only. As such, the values from any non EU insurance subsidiary brought in with deduction and aggregation method, using local regulatory values, should not be reflected in those cells. Those values would only be reflected in the calculation of the “Ratio of Eligible own funds to SCR including other financial sectors' own funds and capital requirements” (cell A55B from the preparatory phase template).
Please note that cells have been added and the situation made clearer in the last version of the template.