Question ID: 2765
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Validations
Status: Rejected
Date of submission: 17 Aug 2023
Question
Is BV374 to be deleted or changed as loans on policies will get further CI codes (87, 88) due to delegation 2023/894?
Background of the question
There might be a mismatch between delegation 2023/894 and validation rule BV374 regarding loans on policies (CIC 86, 87, 88). Due to 2023/894 loans on policies may get the CI codes 86, 87 or 88 and are to be reported in "Loans on policies" item in S.02.01. Due to validation BV374 the value in the balance sheet position "Loans on policies" has to be equal to the sum of assets with CI code 86. This will never match, if you have loans on policies with CI code 87 or 88. Furthermore, changing BV374 in a way to imply CI codes 87 and 88 will not work either, as there are mortgages with CI codes 87 and 88 that have to be reported in a different item in S.02.01.
EIOPA answer
EIOPA confirms the issue as the R0240 and R0250 may not match perfectly to CIC codes 86, 87 and 88. Please note that EIOPA has deactivated the validation in question.