Pension fund ECB / EIOPA reporting - implications for asset managers

What is new?

Publication in 2018 of Regulation (EU) 2018/231 on statistical reporting requirements for pension funds (ECB/2018/2) requires national central banks (NCBs) to collect statistical data from pension schemes on their assets and liabilities, including look-through on collective investment funds (hereafter referred to as “ECB reporting”)

In accordance with article 35 of Regulation (EU) No 1094/20101, EIOPA requests information from the national competent authorities (NCAs) with regard to the provisions of Directive (EU) 2016/23412 (IORP Directive). The EIOPA issued guidelines EIOPA BoS/18114 regarding provision of occupational pensions information, including look-through on collective investment undertakings (“CIUs”)

Which pension funds are in scope?

ECB Regulation includes in its scope workplace pension funds (Pilar II pension funds) and private pension funds (Pilar III pension funds) while EIOPA reporting only includes Pilar II pensions funds

The NCBs may give some derogations for “small pension funds” to submit on an annual basis and the non-detailed reporting

What does it mean for Asset Managers?

For your collective investment undertakings: provided that the look-through is required by your pension fund investor, you may be required to provide statistical data on the funds’ underlying assets on an annual basis

For your segregated accounts / investment mandates: as assets are held directly by your pension fund investor, you may be required to assist your pension fund investor and provide statistical data on the list of assets and investment income on a quarterly and annual basis

In both cases the data reporting would include the necessary information needed to compile the templates issued by EIOPA, with extra data points required for ECB reporting

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Although the detailed quarterly and annual data will be collected through XBRL (eXtensible Business Reporting Language) by NCBs, pension funds may request data from their asset managers in an Excel or CSV format

Exemptions is allowed for the look-through requirement on UCITS for a transitional period that still needs to be determined by EIOPA

Exemptions may be allowed until Q1 2020 by NCBs for quarterly reporting regarding the look-through on CIUs others than UCITS

What is the reporting timeline?

The first quarterly reporting to NCBs and NCAs will occur during Q4 2019 based on Q3 quarter-end holdings, whereas the first annual reporting will be based on 2019 year-end holdings

First Quarterly reporting will be due to NCBs / NCAs by 10 weeks after quarter-end, therefore we expect asset managers to be required to report within 4 weeks after quarter-end. The quarterly reporting due date would be reduced to 9 weeks starting end of March 2019

First Annual reporting will be due to NCBs / NCAs by 20 weeks after 2019 year-end, therefore we expect asset managers to be required to report within 6 weeks after year-end. The annual reporting due date would be reduced every year by 2 weeks, to reach 14 weeks after 2022 year end

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How we can help

The data points and the format of the reporting template are very close to the Solvency II Quantitative Reporting Template applicable to the insurance industry. Leveraging on 12 years of experience in regulatory reporting for the asset management industry, we are integrating a specific ECB / EIOPA module within our Solvency II TPT & QRT reporting platform, planned for go-live by end of Q2 2019

We would be happy to assist you the quarterly or annual compilation and dissemination of ECB / EIOPA reporting for your investment funds or segregated portfolios; please reach out to us for a call or demo

Please note the Central Bank of Ireland has recently published information and guidance on the topic on its website. Should you like further information around our capabilities regarding regulatory reporting services please feel free to contact us or to visit our website.