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QA2021-51 - intragroup reporting LDR-OpCo

QA2021-51 - intragroup reporting LDR-OpCo

Owned by SRB Services
Feb 01, 2024
Atribute Detail
Resolution Reporting Subject Matter Guidance
Guidance Documents Intragroup-liabilities
Taxonomy -
Unique Identifier

QA2021-51

Question


When an OpCo reports the LDR at sub-consolidated level (so LDR-CON), should it consider the liabilities from the holding (so the ultimate parent entity) as intragroup liabilities and report them accordingly in T01 (c013x) and T03? or should those liabilities not be reported in T03 (those intragroup liabilities are in the prudential and accounting scope at parent level)?


Response


According to the LDR Guidance, "[e]ntities to be considered as intragroup are those entities that - in line with the definition of column c013x of T01.00 - belong to the accounting scope of consolidation of the ultimate parent entity. As a result, these liabilities shall not be reported under the detailed tabs T04.00 through T06.00 and T08.00. Derivatives are specific in nature and should not be reported under T03.01, but always in T07.00 as applicable." Also, specific reporting requirements for column c013x of T01.00 clarify that: "c013x –Of which Intragroup Liabilities from entities within the accounting scope of consolidation of the ultimate parent entity. As opposed to the reporting scope, this includes all entities that are not covered by prudential consolidation, but are however covered by the accounting scope of consolidation of the ultimate parent entity as identified in the guidance for r0040 of T99.00. Thus, the highest level of consolidation would not de facto be empty but would contain any liabilities to entities within the accounting scope of consolidation, which are not within the prudential scope of consolidation." In the case at hand, the HoldCo belongs to the accounting scope of consolidation of the ultimate parent entity of the group and it is not consolidated in the LDT-CON reported by the OpCo. As such, provided that the instruments are not derivatives, liability instruments issued by the OpCo and held by the HoldCo should be considered as intragroup.