To the extent that the reports are identical, the number of FS reports should be reduced and instead reference directly to applicable RSR reports. The data requirements should to the extent possible rely on the SII QRT packages as set out in ITS (CP-14-052 and CP-14-055). This information should in turn be sourced directly from the NSAs as recipients of the RSR QRTs. 10. MetLife General Comment We believe that the unit of reporting should be aligned to Solvency II public and private reporting, and this should be explicitly laid out in the guidelines. Agreed, please see new Guideline 3. 11. This comment was submitted as confidential by the stakeholder. 12. OP Group. General Comment We note that the Guidelines are not clear in the case where the insurance undertakings belong to the group of the mixed financial holding company which is exempted from the Solvency II group supervision according to Article 213(4 or 5) of the Directive and only the provisions of the Directive 2002/87/EC (FICOD) are applied in the group level. In this case it is possible that the undertaking belongs also to the insurance or reinsurance group but which is not reporting according to Solvency II. If this exemption is applied in Solvency II the same exemption shall be applied also in the Financial Stability Reporting in order that the undertakings shall not be reporting Solvency II in the level of the individual undertaking but Finanacial Stability in the level of the group. Financial Stability Reporting should supplement the Solvency II reporting. If the reporting levels differ there s nothing to be supplemented. In this case, there would be no financial stability reporting for the group. However, if the undertaking individually reaches the size threshold, it should report for financial stability purposes since it does not belong to a group which reports for these purposes. 13. RSA Insurance Group plc General Comment We should like to express our appreciation to EIOPA for having produced such an extensive package. The package does provide much clarification where previously there was little; and it serves to provide a very useful basis to help firms prepare for SII implementation. As per EIOPA’s request, our comments are restricted only to those areas which have seen changes from what was consulted upon in Noted.
1.32. Once the rules for determining the 50%market coverage reporting sample, we do not see how it serves further the Financial stability purposes to enlarge that population at the discretion of the supervisors. Having regards to our above comments, this guideline should be deleted. 44. IRSG Guideline 8 Under 1.34 fourth and last lines: „threshold stated in Guideline 2… the regular reporting requirements of …..” Under 1.35 first line and second last line: „on the basis of the list defined in paragraph 1.34 … will report on the basis of the market share…” OK 45. IRSG Guideline 9 Under 1.36 third line:”to report on the basis of the market share requirement provided in Guideline 2,…” Note that the market share requirement is no longer applied. 46. Deloitte Touche Tohmatsu Guideline 9 We propose that”reasonable time” should be defined, and firms should be given at least three months notice if they are to be included within scope for financial stability reporting. Note that the market share requirement is no longer applied. 47. Insurance Europe Guideline 9 1.36. The notification by NCAs to undertakings within a „reasonable timeframe”, to report under the market share requirement leaves too much leeway for NCAs that could end up as a time pressure for the undertaking if the ultimate time allotted to report was short. The timeframe needs therefore to leave at least 3 months for the undertaking. Note that the market share requirement is no longer applied. 48. MetLife Guideline 9 The notification to undertakings by NCAs should be time bound, to avoid pressures in case of delays. Given the significant impact on the reporting process/ calendar of a group, it should allow at least 6 months of lead time from when a notification is made to when reporting is first required for submission. Note that the market share requirement is no longer applied. 49. IRSG Guideline 10 Under 1.39 fourth and fifth lines: „ensure that the data reported reflect the best assessment oft he current financial and operational condition of the entity and are based…” Under 1.39 a): Why is threre a reference to controls and audit? Does regular supervisory reporting have to be audited? The reference was to internal audit, removed in guideline. It is expected that the supervisory reporting follows
therefore not be made public. 54. Investment & Life Assurance Group (ILAG) Guideline 10 Paragraph 1.39 states that simplifications employed in the preparation of data for reporting should remain consistent over time, yet this appears somewhat inconsistent with the guidance of 1.41 in that improvements in process should be made over time so as to reduce discrepancies between FST and QRT reporting. We feel that paragaph 1.39 should be amended to acknowledge that changes in simplifications are permitted when they are to satisfy the requirements of other guidelines. Please see answer to comment 50. 55. MetLife Guideline 10 Further guidance should be included, in the context of a group with numerous non-significant subsidiaries, and to what extent simplification would be appropriate. In order to allow undertakings to make the most useful simplifications in their case, the best effort principle is kept at relatively high level. 56. IRSG Guideline 11 Under 1.42 third and fourth lines: „regular supervisory reporting on the basis of …However, the relevant national supervisory authority…” We wonder if there is no need to explain the simplifications used under a best effort approach in qualitative terms anyway and not only on request of the NSA (see also GL 10). See answer to comment 51 57. Federation of European Accountants (FEE) Guideline 11 We wonder if there is any need to explain the simplifications used under a best effort approach in qualitative terms and not only on request of the NSA (see also GL 10). Please see answer to comment 51. 58. GDV Guideline 11 In light of the fact that fulfilling reporting requirements under Solvency II already poses a heavy administrative burden on insurance companies, financial stability reporting and SII-reporting should be streamlined and divergent reporting requirements should be avoided. Agree, the final Guideline reflects a balanced approach between burden and EIOPA responsibilities, and includes increased consistency with prudential reporting. 59. Insurance Europe Guideline 11 There should be no requirement to explain the difference between information submitted for financial stability purposes and regular See answer to comment 51.
instead of the principles EIOPA formulates. EIOPA performance reports will be used as and when EIOPA reveals the purpose of the deviation and issues a set of standards without errors, in line with the stated purpose. Furthermore, this template elicits the following comments: EIOPA should clarify whether this template should be completed on a year to date basis or in a discrete manner Cell C0100 - Net gains and losses: Definition of gains and losses as per LOG guidance is; “The gains and losses are calculated as the difference between selling or maturity value and the value according to article 75 of Directive 2009/138/EC at the end of the prior reporting year end (or, in case of assets acquired during the reporting period, the acquisition value).” This is not in line with the net gains and losses calculation under IFRS and hence, additional effort is required to acquire this information. We ask EIOPA to align net gains and losses calculation with under IFRS to achieve consistency. We believe that the different definition introduces significant complexity into the process and question its real value given that unrealised gains are now also being reported C0100 and C0110: EIOPA must clarify whether loss amounts should be filled out in negative or whether the formula accounts for the signs. C0070 and C0080 Dividends and interest. Should the amounts disclosed for dividends and interest be shown gross or net of tax? Definitions need to be improved - ought to refer to income “receivable” during the year; or income “received and accrued at the period end, less amounts accrued during the previous period.” There are errors in the current version of the templates: o The LOG file still partially refers to cash based reporting.