Regulatory Reporting for AIFMD, CRD IV, Solvency II, MiFID II, FATCA and AnaCredit

FAQ



What is Solvency II?

Solvency II is a directive by the European Union. Its purpose is to regulate the European (Re)insurance business. Its main objective is to observe the amount of capital that European Insurance companies must hold in order to reduce the risk of insolvency.

To whom does it apply?

The regulation applies to Insurance and Reinsurance companies running their operations in the European Union and fulfilling certain criteria (one of the criteria is gross written premium income of more than €5 mn).

Who is the Regulatory Authority?

The regulatory authority is the European Insurance and Occupational Pensions Authority (EIOPA). Companies have to file their reports with the relevant National Competent Authority (NCA) of the country within the European Union.

What is the Solvency II Framework?

The framework is a structure in which the reporting requirements are classified. Solvency II reporting is based on three pillars.
Pillar 1 deals with quantitative information such as the measurement of capital, assets and liabilities. It includes the calculation of Own Funds (including balance sheet), Minimum Capital Requirement (MCR) and Solvency Capital Requirement (SCR). It provides a market-consistent valuation of balance sheet, and a more standardized assessment of risk based requirements.
Pillar 2 contains more qualitative information pertaining to the company’s Own Assessment of Risk and Solvency (ORSA) and contains details on Corporate and Risk Governance. It is required for supervisory review.
Pillar 3 deals with the reporting or disclosure requirements of the information contained in the first two pillars. It is required to bring in market discipline and transparency within the industry.

What is required to be filed?

The companies have to file a range of reports which can be classified broadly as Regular Supervisory Reports (RSR) and Solvency and Financial Condition Reports (SFCR). The RSR is a confidential report filed with the supervisory authority while SFCR contains public information.
The required information has to be provided in the form of Quantitative Reporting Templates (QRTs). The QRTs comprehensively cover all financial and risk information. There are several templates segregated into different groups based on the type and reporting structure of (Re)insurance company (for example, Group reporting, Solo reporting, Third country branch reporting etc.). Again among groups, templates are further segregated into annual and quarterly. Solvency II has well-defined entry points for each of the report type and report frequency.
In addition to the QRTs to be filed as per EIOPA guidelines, certain jurisdiction in EU includes additional reporting at NCA level (For example Ireland, UK, Malta etc.) in the form of National Specific Templates (NSTs).

What is the frequency and level of filing?

The filing has to be done on a quarterly basis for a set of QRTs and on an annual basis for another set of QRTs.

What is the format for filing?

The reports with EIOPA are to be filed in the XBRL (eXtensible Business Reporting Language) format. The taxonomy to be used for filing has been published by the EIOPA and is based on a data point model. NST reports are to be filed either in XBRL format or any other format depending upon the jurisdiction (For example XBRL format in Ireland and excel format in Malta and UK).

Who administers XBRL and where can I get more information about XBRL?

Standards for XBRL are established and administered by an international organization called XBRL International, with national jurisdictions in various countries. Organizations such as Eurofiling are not national jurisdictions. They are consortiums that help regulators, filers and XBRL companies by providing a common platform for connecting with each other and by developing software, help and support documents and sometimes, even new taxonomies and models. The regulators for the various European XBRL regulations (namely EBA and EIOPA) also have information about taxonomies, filing eligibility and deadlines.

What is the timeline for reporting?

The Solvency II reporting has become mandatory effective 1st Jan 2016. All companies will have to file their day one submissions within a period of 20 weeks (for the Solo level) and 26 weeks (for the Group level). The first quarterly submissions for the quarter ending 31st March 2016 have to be filed within a period of 8 weeks (for the Solo level) and 14 weeks (for the Group level).

A summary of the timeline for reporting is given below[1][2]:

Submission Period

Filing deadline

Solo

Group

Solo

Group

Day I submissions (as on 1 Jan 2016)

20 weeks

26 weeks

20-May-16

1-Jul-16

Quarterly submissions

8 weeks

14 weeks

26-May-16

7-Jul-16

Annual submissions

20 weeks

26 weeks

20-May-17

1-Jul-17

[1] Deadline for NST reporting could vary depending upon the jurisdiction.
[2] Above dates are based on the (Re)insurance companies following calendar year as their fiscal period.

Can I access your web based application from any location?

Yes, you can access our application from any location after passing the user authentication. However at your request, this application can also be installed within the firewalls of the Organisation in which case you can use the application from any location provided it is within the Organisation’s firewall.

What does one-time implementation includes?

One-time implementation includes studying the data source, building an ETL layer with our preconfigured adapters and integrating with our application.

How long it would take to do the implementation?

Implementation would normally take 2 to 6 weeks depending upon the size and complexity of data source.

Does your output comply with necessary validation rules?

Our software is built to meet all the business rules provided by EIOPA for QRTs and by each NCA for reporting NSTs.

What is BASEL III?

The Basel Committee develops comprehensive set of reform measures which ensures that the international banks maintain adequate capital. After the financial crisis the Basel Committee reviewed its capital adequacy standards and created the third configuration of its standards known as BASEL III.
Basel III is not a law but an evolving set of international standards which need to be transposed into EU (and national) law. The Commission’s legislative proposals on CRD IV seek to transpose the Basel III standards into EU law.

What is CRD IV and CRR?

The Capital Requirements Directive (CRD IV) and Capital Requirements Regulation (CRR) are the EU directive and regulation that set forth the capital adequacy rules for credit institutions and investment firms collectively referred as ‘firms’. CRR took effect on 1 January 2014 throughout the EU. CRR regulates areas such as the calculation of capital base, RWA, liquidity and large exposures and need not be implemented in national law. CRD IV treats rules on remuneration, governance, the dialogue between credit institutions and the supervisory authority on the determination of the solvency need, among other things. CRD IV took effect on 31 March 2014 in all the countries in EU. The new rules are intended to implement the latest global banking standards in Basel III so as to create more consistent regulations across the EU.

To whom does CRD IV apply to?

The application of CRD IV is entirely dependent on the regulatory activities. CRD IV Directive will apply to Credit Institutions; and to Investment Firms that are involved in two or more of following Markets in Financial Instruments Directive (MiFID) activities:

  • Dealing on own account
  • Underwriting of financial instruments
  • Placing of financial instruments
  • Operating a Multilateral Trading Facility
  • Custodianship and related services such as cash/collateral
CRD IV does not apply to Investment firms that not caught by the above and they continue to remain under CRD III.

Who is the Regulatory Authority?

The regulatory authority is the European Banking Authority (EBA). Companies have to file their reports with the relevant National Competent Authority (NCA) of the country within the European Union.

What’s the timeline and implementation of CRD IV EU wide?

The timelines as agreed in the Basel Committee and in the framework of the G20: entry into force of the new legislation on 1 January 2014, and full implementation on 1 January 2019, in line with the international commitments.

Framework Version

Taxonomy Release Date

Reference Date

Deadline

COREP

FINREP

Asset Encumbrance

Funding plans

SBP's

Previous versions

2.0

Dec-13

Mar-14

Jul-14

2.0.1

2.0.1

 

 

 

2.1

Mar-14

Oct-14

Oct-14

2.0.2

2.1.0

1.0.0

 

 

2.2

Aug-14

Jan-14

Jan-14

2.0.3

2.1.1

1.0.1

1.0.0

2.3

Q4-2014

Jul-15

Jul-14

2.1.0

2.1.2

1.0.0

Current version

2.4

Q2-2015

Dec-15

Jan-15

LR,LCR Changes

 

 

 

 

Future releases

2.5

Q4-2014

Q2-2016

Amendment/Correction

2.6

Q2-2016

Q4-2016

EBA’s Review

2.7

Q4-2016

Q2-2017

Amendment/Correction

What is XBRL?

eXtensible Business Reporting Language (XBRL) is a markup language used to make business and financial data readable by computers. Just as HTML allows text, images and multimedia to be read by internet browsers, XBRL allows financial data to be read and analysed by specialised software, by marking up the data with relevant tags.
By filing your data in XBRL, you allow computers to understand your data. This, in turn, allows the computer to analyse your data in comparison with data from other providers to give consumers, investors, regulators and indeed, you, actionable insights into your financial and risk condition, thus protecting both consumers and investors from bad investments.

Who administers XBRL and where can I get more information about XBRL?

Standards for XBRL are established and administered by an international organization called XBRL International, with national jurisdictions in various countries. Organizations such as Eurofiling are not national jurisdictions. They are consortiums that help regulators, filers and XBRL companies by providing a common platform for connecting with each other and by developing software, help and support documents and sometimes, even new taxonomies and models. The regulators for the various European XBRL regulations (namely EBA and EIOPA)also have information about taxonomies, filing eligibility and deadlines.

When do I need to make my XBRL filings?

For CRD IV filings to the EBA, there are monthly, quarterly and annual templates as applicable. The filing frequency and deadlines for filings of various reports is as follows:

Report

Reporting Frequency

Reporting Reference Dates

Submission Remittance

COREP (excluding LCR)

Quarterly

Last day of each calendar quarter (31st Mar, 30th Jun, 30th Sep and 31st Dec)

Within 42 days (12th May, 11th Aug, 11th Nov and 11th Feb)

FINREP, Funding Plans*, Asset Encumbrance and Supervisory Benchmarking Portfolios**

Quarterly, Semi-annually and Annually

COREP – LCR

Monthly

Last day of Each Month

Within 15 Days

* Funding Plans with a reference date of 31 December 2015 data should be submitted by 31 March 2016
** SBP templates with a reference date of 31st December 2015 data should be submitted by 11 April 2016

Can I access your web based application from any location?

Yes, you can access our application from any location after passing the user authentication. However at your request, this application can also be installed within the firewalls of the Organisation in which case you can use the application from any location provided it is within the Organisation’s firewall.

What does one-time implementation includes?

One-time implementation includes studying the data source, building an ETL layer with our preconfigured adapters and integrating with our application.

How long it would take to do the implementation?

Implementation would normally take 2 to 6 weeks depending upon the size and complexity of data source.

Does your output comply with necessary validation rules?

Our software is built to meet all the EBA business rules.

What is AIFMD?

The Alternative Investment Fund Managers Directive (AIFMD) is a European financial directive which was published in the Official Journal of the European Union on July 1, 2011 to achieve following objectives:

  • Prevent market instability and systemic in the financial system in EU
  • Improve investor protection through new disclosure rules and mandatory reporting
  • Harmonization of rules deregulating national barriers

To whom does it apply?

The AIFMD applies to Alternative Investment Fund Managers (AIFM) which includes hedge funds, private equity funds, real estate funds, among others operating within European Union (EU) or marketing to investors in EU. Fund whose Asset under Management (AuM) exceeds €100 million will come under the reporting requirement.

Who is the Regulatory Authority?

The regulatory authority is the European Securities and Markets Authority (ESMA). Companies have to file their reports with the relevant National Competent Authority (NCA) of the country within the European Union.

What is required to be filed?

AIFMD requires reporting in Annex IV template about certain information on fund investments and trade activities including but not limited to AuM, principal markets in which the AIF trade, principal investments, Investor ownership information, Fund returns, Fund exposure and Margin details.

What is the frequency and level of filing?

The filing has to be done on a quarterly basis.

What is the format for filing?

The reports with ESMA are to be filed in the XML (eXtensible Markup Language) format. XML is a markup language that defines a set of rules for encoding documents in a format which is both human-readable and machine-readable.

What is the frequency of reporting?

Filing frequency depends on the AuM value calculated as per ESMA’s guidelines. Refer to following table:

AuM calculated as per ESMA’s guidelines

Reporting frequency

Greater than €100 million and up to €500 million

Annually

Greater than €500 million and up to €1 billion

Semi-annually

Greater than €1 billion

Quarterly

What is the timeline for reporting?

Deadline for filing the Annex IV templates is 30 days from the end of quarter (quarterly filing) or half-year (half-yearly filing) or year (annual filing) as the case may be.

Can I access your web based application from any location?

Yes, you can access our application from any location after passing the user authentication. However at your request, this application can also be installed within the firewalls of the Organisation in which case you can use the application from any location provided it is within the Organisation’s firewall.

What does one-time implementation includes?

One-time implementation includes studying the data source, adding asset types to the database and integrating with our application.

How long it would take to do the implementation?

Implementation would normally take 1 to 2 weeks depending upon the size and complexity of data source.

Does your output comply with necessary validation rules?

Our software is built to meet all the business rules provided by ESMA.

What is MiFID II?

The Markets in Financial Instruments Directive (MiFID II) is the EU legislation that regulates firms who provide services to clients linked to ‘financial instruments’ (shares, bonds, units in collective investment schemes and derivatives), and the venues where those instruments are traded.

To whom does MiFID II apply to?

MiFID II is applicable to Investment firms that execute transactions in financial instruments that are traded in the trading venue or whose underlying is traded in the trading venue.

Who is the Regulatory Authority?

ESMA is the regulatory authority of MiFID II.

What is required to be filed?

  • 65 fields comprising of transaction details
  • Buyer and seller details
  • Instrument details
  • Trade and related details of the traded instruments

What is the frequency and level of filing?

Daily.

What is the format for filing?

We follow XML format for NCAs and Excel format for the ARMs

What is the frequency of reporting?

Daily.

What is the timeline for reporting?

8.00 PM CET (Central European Time) on T+1

Can I access your web based application from any location?

Yes, it is a cloud based application. It can be accessed from anywhere if there is an internet connection.

What does one-time implementation includes?

Identification of the relevant data and mapping to the source data.

How long it would take to do the implementation?

Depends on the source system.

Does your output comply with necessary validation rules?

Yes, the output is compliant with all the validation rules provided by ESMA.

What is FATCA?

The Foreign Account Tax Compliance Act (FATCA) is used to combat tax evasion by U.S. persons holding accounts and other financial assets offshore.

To whom does FATCA apply to?

  • FATCA will also require certain foreign financial institutions to report directly to the IRS information about financial accounts held by U.S. taxpayers or by foreign entities in which U.S. taxpayers hold a substantial ownership interest.
  • The reporting institutions will include not only banks, but also other financial institutions, such as investment entities, brokers, and certain insurance companies. Some non-financial foreign entities will also have to report certain of their U.S. owners

Who is the Regulatory Authority?

Internal Revenue Service (or IRS) is the regulatory authority of FATCA

What is required to be filed?

Summary of tax items attributable to specified foreign financial assets and detailed information for each foreign deposit and custodial account

What is the frequency and level of filing?

Annual basis

What is the format for filing?

XML format

What is the frequency of reporting?

Annually

What is the timeline for reporting?

Within 90 days from the end of calendar year

Can I access your web based application from any location?

Yes, it is a cloud based application. It can be accessed from anywhere if there is an internet connection.

What does one-time implementation includes?

The one-time implementation includes a brief study on the client source systems, extraction of relevant data which can be directly loaded as an input to the solution

How long it would take to do the implementation?

The time taken to do the implementation depends on the complexity involved

Does your output comply with necessary validation rules?

Yes, the output is compliant with all the validation rules provided by IRS


Specialisti in XBRL e reportistica regolamentare

DataTracks prepara oltre 14,000 dichiarazioni XBRL ogni anno per l'archiviazione con regolatori come SEC negli Stati Uniti, HMRC nel Regno Unito, Revenue in Irlanda, rapporti di conformità Eurofiling in Europa, ACRA a Singapore e MCA in India. Grazie alla nostra esperienza nella preparazione di oltre 172,000 rapporti di conformità, le nostre soluzioni e servizi sono progettati per garantire qualità, affidabilità e facilità d'uso.

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