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Questions and answers
During the preparatory phase the PRA invited regulatory reporting questions via its Solvency II industry working group. Questions have also been received directly from firms via email. To help insurance firms and other organisations working on Solvency II with questions they may have on the submission of information, both in the preparatory phase and at implementation, questions were answered and a selection have been published in the three Q&A documents in Key Resources below.
- The answers to the first set of questions, numbers 1 – 11, were published in February 2014, with information available at the time.
- The answers to a second set of questions, numbers 12 – 25, were published August 2014, with information available at the time.
- The answers to a third set of questions, numbers 26 - 43, were published September 2015, with information available at the time.
To raise further questions firms should address them to an appropriate industry representative of the regulatory reporting industry working group.
If firms are not represented at the working group by a member organisation then they should submit their question to PRASIIregulatoryreporting@bankofengland.co.uk
Solvency II reporting clarifications
On the 18 December 2015, the PRA set out the basis of preparation on which it will accept look through reporting for Collective Investment Undertakings under template S.06.03.
Basis of preparation on which the PRA will accept look through reporting for Collective Investment Undertakings under S.06.03
Legal Entity Identifiers
EIOPA published its Guidelines on the use of Legal Entity Identifiers (LEIs) in September 2014, (EIOPA BoS-14-026, see External Links). The Guidelines recommend that LEI codes should be used as unique identification codes for all institutions under the PRA’s supervisory remit. The PRA intends to comply with these Guidelines.
In the UK, LEI codes are allocated and maintained by the London Stock Exchange (see External Links), which has been endorsed by the UK’s Regulatory Oversight Committee (ROC) as an authorised Local Operating Unit (LOU) for the UK.
The PRA requests all firms within the scope of Solvency II to request a LEI code by 30 June 2015, at the latest, while all other insurers should request a LEI code by 30 June 2016.
For firms that are part of a group, the PRA requests that all entities within the group obtain a LEI code, including holding and dormant companies. The PRA acknowledges that this may prove burdensome for some firms; however believes the advantages of using LEI codes for regulatory reporting across borders and the financial industry outweighs this.
Should entities within a firm’s group be unable to obtain LEI codes, the PRA suggests the firm follow EIOPA’s instructions on p84 of its document titled “Navigating through the Solvency II reporting and disclosure package: Note accompanying the public consultation on the Guidelines and ITS” (see Related Links) which states:
“For non-EEA undertakings and non-regulated undertakings within the group, identification code provided will be provided by the group. When allocating an identification code to each non-EEA or non-regulated undertaking, it should comply with the following format in a consistent manner: identification code of the parent undertaking + ISO 3166-1 alpha-2 code of the country of the undertaking + 5 digits”
When a code constructed in this manner is used within the reporting templates, the ‘Type of Code of Undertaking’ should be recorded as a ‘specific code’ rather than a LEI.
The PRA requests all firms to notify their usual supervisory contact to confirm that a LEI code has been requested, as appropriate.