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S.36.01 — IGT — Equity–type transactions, debt and asset transfer

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S.36.01 — IGT — Equity–type transactions, debt and asset transfer

General comments:

This template relates to the information that groups are requested to provide at least annually.

This template shall report all (significant, very significant and transactions required to be reported in all circumstances) intra-group transactions between entities of a group related to equity, debt, reciprocal financing1 and asset transfers.

These include, but are not limited to:

  • equity and other capital items including participations in related entities and transfer shares of related entities of the group;
  • debt including bonds, loans, collateralised debt, and other transactions of similar nature e.g. with periodic pre-determined interest or coupon or premium payments for a predetermined period of time;
  • other asset transfer such as transfer of properties and transfer of shares of other companies unrelated (i.e. outside) to the group.

This template shall include intragroup transactions that were:

  • in-force at the start of the reporting period.
  • incepted during the reporting period and outstanding at the reporting date.
  • incepted and expired/matured during the reporting period.

Where two or more transactions between entities of the group which, from an economic perspective, contribute to the same risk, or, serve the same purpose / objective or are temporally connected in a plan, they shall be considered as a single economic operation.

As such each transaction which is part of a single economic operation shall be reported whenever collectively they are at or above the corresponding threshold for significant intragroup transactions, even though individually the transactions fall below the threshold.

Any element added to significant intragroup transactions shall be reported as a separate intragroup transaction, even if the element in its own right falls below the significant threshold limit. For example, if an undertaking increases the initial loan amount to another related undertaking the addition to the loan shall be recorded as a separate item with its issue date as the date of the addition.

Where the transaction value is different for two transacting parties (e.g. a €10m transaction between A and B where A records €10m but B only receive €9.5m because of transactions costs, of say €0.5m has been expensed) the template shall record the maximum amount as the transaction amount, in this case €10m.

Indirect transactions shall be defined as any transaction shifting risk exposures between entities within the group including but not limited to transactions with special purpose vehicle, collective investment undertakings, ancillary entities or unregulated entities; or entities outside of the group but ultimately risk exposure is brought back or stays within the group. Where there

1 As set out in Article 223 of Directive 2009/138/EC of the European Parliament and of the Council of 25 November 2009 on the takin-up and pursuit of the business of Insurance and Reinsurance

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is a chain of related intragroup transactions (e.g. A invests in B and B invests in C), this transaction shall be reported as an indirect transaction. Therefore A to C transaction shall be reported and the comments shall mention the intermediary step. In the case of a waterfall of transactions, e. g. if “A”-> “B” -> “C”-> “D” where both “B” and “C” are both in the group but unregulated entities, this transaction shall also be reported.

ITEM INSTRUCTIONS
C0010 ID of
intragroup
transaction
Unique internal identification code for each intragroup
transaction. Shall be consistent over time.
C0020 Investor/
Lender name
Name of the entity that is buying the equity or lending
to a related undertaking within the group, i.e. the entity
that recognises the transaction as an asset on its balance
sheet (debit –
balance sheet).
C0030 Identification
code for
investor /
lender
The
unique
identification
code
attached
to
the
investor/buyer/transferee by this order of priority:
-
Legal Entity Identifier (LEI) mandatory if existing;
-
Specific code in case of absence of LEI code.
Specific code:
-
For EEA regulated undertakings other than insurance
and
reinsurance
undertakings
within
the
group:
identification code used in the local market, attributed
by the undertaking’s competent supervisory authority;
-
For
non-EEA
undertakings
and
non-regulated
undertakings within the group, identification code shall
be
provided
by
the
group.
When
allocating
an
identification code to each non-EEA or non-regulated
undertaking, the group shall 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
C0031 Type of code
for investor /
lender
Type of ID Code used for the “Identification code for
investor / lender” item. One of the options in the
following closed list shall be used:
1 –
LEI
2 –
Specific code
NC0040 Sector of the
investor/
lender
If the investor / lender is part of financial sector within
the meaning of Article 2 (8) of Directive 2002/87/EC,
indicate: “banking sector”, “insurance and reinsurance
sector” “investments services sector”.
If the investor / lender is not part of financial sector
within the meaning of Article 2 (8) of Directive
2002/87/EC indicate: “other undertaking of the group”.
C0050 Issuer/
borrower
name
Name of the entity that is issuing the equity/capital
item, or borrowing money (issuing debt), i.e. the entity
that recognises the transaction as a liability or capital on
its balance sheet (credit –
balance sheet).
The
unique
identification
code
attached
to
the
investor/buyer/transferee by this order of priority:
-
Legal Entity Identifier (LEI) mandatory if existing;
-
Specific code in case of absence of LEI code.
Specific code:
C0060 Identification
code for
issuer /
borrower
-
For EEA regulated undertakings other than insurance
and
reinsurance
undertakings
within
the
group:
identification code used in the local market, attributed
by the undertaking’s competent supervisory authority;
-
For
non-EEA
undertakings
and
non-regulated
undertakings within the group, identification code shall
be provided by the group.
When allocating an identification code to each non
EEA
or
non-regulated
undertaking,
the
financial
conglomerate shall 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
C0061 Type of code
for issuer /
borrower
Type of ID Code used for the “Identification code for
issuer / borrower” item. One of the options in the
following closed list shall be used:
1 –
LEI
2 –
Specific code
NC0070 Sector of the
issuer /
borrower
If the issuer / borrower is part of financial sector within
the meaning of Article 2(8) of Directive 2002/87/EC,
indicate: “banking sector”, “insurance and reinsurance
sector” “investments services sector”.
If the issuer / borrower is not part of financial sector
within the meaning of Article 2(8) of Directive
2002/87/EC indicate “other undertaking of the group”.
NC0080 Indirect
transactions
If reported intra-group transaction is part of an indirect
transaction (cf. General comments supra), report the
“ID of intragroup transaction” (C0010) of the related
transaction in this cell. If more than two transactions are
related, the ID code of the first related transaction needs
to be reported as a reference to link all interconnected
transactions.
If the reported IGT is not part of an indirect transaction,
indicate No.
NC0090 Single
economic
operation
If the reported IGT is part of single economic operation
(cf. General comments supra), report the “ID of
intragroup
transaction”
(C0010)
of
the
related
transaction in this cell. If more than two transactions are
related, the ID code of the first related transaction needs
to be reported as a reference to link all interconnected
transactions.
If the reported IGT is not part of single economic
operation, indicate No
This is the identification code of the instrument (capital,
debt etc.) between the two counterparties identified
using the following priority:
-
ISO 6166 code of ISIN when available
ID Code of -
Other recognised codes (e.g.: CUSIP, Bloomberg
Ticker, Reuters RIC)
NC0100 the
instrument
-
Code attributed by the undertaking, when the options
above are not available. This code shall be consistent
over time.
This may be different from the intragroup transaction
code provided in cell C0010.
NC0101 ID Code
Type of the
instrument
Type of ID Code used for the “ID Code of the
instrument” item. One of the options in the following
closed list shall be used:
1 -
ISO 6166 for ISIN code
2 -
CUSIP (The Committee on Uniform Securities
Identification Procedures number assigned by the
CUSIP
Service
Bureau
for
U.S.
and
Canadian
companies)
3 -
SEDOL (Stock Exchange Daily Official List for the
London Stock Exchange)
4
-
WKN
(Wertpapier
Kenn-Nummer,
the
alphanumeric German identification number)
5 -
Bloomberg Ticker (Bloomberg letters code that
identify a company’s securities)
6 -
BBGID (The Bloomberg Global ID)
7 -
Reuters RIC (Reuters instrument code)
8 -
FIGI (Financial Instrument Global Identifier)
9 -
Other code by members of the Association of
National Numbering Agencies
99 -
Code attributed by the undertaking
Identify the type of instrument.
The following close list shall be used:
NC0110 Type of
instrument
1 -
Bonds / Debt
2 -
Equity type
3 -
Other asset transfer
Identify the instrument. The following close list shall be
used:
1 -
Bonds / Debt –
collateralised
NC0120 Instrument 2 -
Bonds / Debt –
uncollateralised
3 -
Equity type –
shares / participations
4 -
Equity type –
others
5 -
Other asset transfer –
properties
6 -
Other asset transfer –
others
NC0130 Issue date This is the earlier of the transaction/debt issue date or
the date the intragroup transaction is effective from, if
different from the issue date.
The date shall follow the ISO 8601 (yyyy-mm-dd)
format.
NC0140 Maturity
date
Identify the ISO 8601 (yyyy-mm-dd) code of the date
when the transaction expires / reaches maturity if
applicable.
For intragroup transaction
with no maturity
-
date use “9999-12-31”.
For perpetual securities use “9999-12-31”
-
NC0150 Currency of
transaction
Identify the ISO 4217 alphabetic code of the currency
in which the transaction took place.
NC0160 Amount at
transaction
date
Amount of the transaction at transaction date reported
in the reporting currency of the group.
NC0170 Amount at
reporting
date
Outstanding amount of the transaction at the reporting
date if applicable e.g. for debt issue, reported in the
reporting currency of the group. If there has been a full
early settlement/prepayment, the balance of contractual
amount shall be zero.
NC0180 Value of
collateral
The value of collateral for collaterised debt or asset
value
for
intragroup
transaction
involving
asset
transfer, reported in the reporting currency of the group.
NC0190 Amount of
dividends/
interest/
coupon and
other
payments
made during
reporting
period
This cell shall capture any payments made in relation to
the intragroup transaction s recorded in this template for
the reporting period (6 months up to the reporting date).
This includes, but not limited to:
Dividends for the current year including paid
-
or declared but unpaid dividends.
Any deferred dividends from previous years
-
paid during the reporting period (i.e. any
deferred dividends paid that impacted the P&L
for the reporting period).
Interest payments made in relation to debt
-
instruments.
Any other payments made in relation to the
-
intragroup transaction s that are reported in this
template, e.g. charges on asset transfers.
Amount of total tops-ups if applicable, i.e. total
-
additional money invested during the reporting
period such as an additional payments on
partly paid shares or increasing loan amount
during the period (when reporting tops-ups as a
separate item).
This amount shall be reported in the reporting currency
of the group.
C0200 Coupon/
Interest rate
The interest
or
coupon
rate
as a
percentage,
if
applicable. For variable interest rate, this shall include
the reference rate and the interest rate above it.

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C0210 Comments Comments shall contain:
a notification if the transaction has not been
-
performed at arm’s length
any other relevant information regarding the
-
economic nature of the operation
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