By far the most important new legislation in recent years for the European insurance and pensions sector is undoubtedly Solvency II. A key objective of the risk-based supervisory system is to make investment risks transparent.
When calculating the solvency capital (SCR), which, for example, has to be provided by the respective insurer to cover the risks taken, it is not distinguished according to whether positions are held directly or in the form of funds indirectly. For both special funds and mutual funds, the lack of transparency has a negative impact on the required solvency capital.
In the focus of reporting to the supervisory board are the so-called "Quantitative Reporting Templates" (QRTs). Solvency Report S.06.03 or PF.06.03.24 (reporting requirement to IORPs) requires a review of all funds acquired. In connection with the obligation to review the funds that are held under unit-linked life insurance (FLV) and umbrella funds.
Insurers who have invested less than 30% of their investments in funds (including FLVs) are exempt from the quarterly submission requirement of the Fund Review Report. However, this exemption does not release from the obligation to carry out regular SCR calculations on the basis of fund review data at the stock level.
Due to the aforementioned obligations, the fund companies are required to provide the data at regular intervals or to obtain them at regular intervals. The fund companies rely on umbrella funds to integrate the target fund data, which are managed by externals and thus require similar to the reportable insurance companies or IORPs to data recipients.