sophisticated systems will be required collect data from its original source, store and match it to the various reporting templates. Reporting requirements must be determined well in advance of the entry into force date. Please refer to section 4.7 for GDV comments on the time required for implementation. For the Solvency II balance sheet, additional costs might be incurred to report the balance sheet in a fast close timeframe. 11. XL Group plc BS-C1 – Costs Overall, significant IT costs will be incurred in building the systems necessary to source, store, validate and report the detailed inforamtion required for Solvency II Pillar 3 reporting. Additional costs are likely to be incurred to report the Solvency II balance sheet to a fast close timeframe. Noted. Please see comment n. 6 12. BS-C1 – Disclosure The publication of a “solvency balance sheet” does not seem appropriate as mutual entities are not listed in the financial markets. In our view, the primarily objective of defining a “solvency balance sheet” is the assessment of the amount of eligible own funds. Only the eligible amount of own funds and major changes made to main elements of equity should be publicly disclosed. Other specific elements such as investments should be subject to limited disclosure. BS-C1 template is a central element of disclosure on financial & solvency position. Such template needs to be comparable. Template also helps to understand information. 13. German Insurance Association (GDV) BS-C1 – Disclosure As previously mentioned differences in scope and national accounting methodologies and will have a large impact on this template and EIOPA’s requirement to perform a quantitative reconciliation. Only the Solvency II value column should be publically disclosed along with a narrative statement explaining differences that have arisen between the two. This would continue to fulfil EIOPA’s envisaged benefits in terms of market transparency. Please see comment n. 1 14. KPMG BS-C1 – Disclosure The draft level 2 implementing measures require non-insurance financial institutions (banking entities, investment firms etc.) to be The SII BS layout is different than the one
liabilities that are not reported on a quarterly basis (latest annual BS-C1). AMICE members reiterate their opposition to any request for quarterly balance sheets at both solo and group levels. Such publication would be tremendously burdensome and without any value added for either the supervisor or the undertaking. We believe that the purpose of requesting the submission of more frequent than annual information is to support the solvency monitoring as part of the Supervisory Review process (SRP) and (re)insurance undertakings’ own internal strategic management needs. The information needed for the continuous monitoring of (re)insurance undertakings’ solvency positions will be provided by a new powerful tool, the ORSA. The ORSA will allow the assessment of own funds and technical provisions on a continuous basis by using proportionate methodologies and proxies, hence on a quarterly basis, but without the need for recourse to a formal balance sheet that would be very costly to establish. other criteria to define thresholds would not overcome this difficulty. On the other hand, to calculate Own funds quarterly, undertakings will have to calculate the entire balance sheet with the same frequency. Taking all this into account, EIOPA believes that, both from a supervisory point of view and from an operational point of view for undertakings, the request of the quarterly without exemptions is the best approach. Quarterly reporting is to be an to SRP. The primary objective of the ORSA is undertaking’s internal assessment. ORSA is not performed for supervisor’s purposes.
19. CEA BS-C1 – Frequency We support EIOPA’s direction in applying a clause to limit quarterly reporting of the balance sheet however we believe that quarterly reporting should not be required as standard. Reporting of the balance sheet is very much reliant on data from other templates which are not calculated/reported at the same frequency therefore to require quarterly reporting on a systematic basis will be problematic. It should however be stressed that deferred taxes (assets or liabilities) would be mechanically modified due to changes in assets and liabilities. The explanation of changes in the reconciliation reserve should be analysed with changes in assets and liabilities net of taxes. For example: if assets increase +10 over one year, with no change to liabilities, for a country where the tax rate is 30% then the “logical” impact on the reconciliation would be this case, the changes in the reconciliation reserve should be considered as “explained” by the changes in assets, and the exemption for quarterly reporting should apply. More clarification on what EIOPA interpret “explained” would be helpful, it may be possible to use a different exemption clause for example, a comparison between the delta of change in technical provisions and assets with the delta of total available own funds. Please see answer to comment 15. Valuation rules are to be determined in future L2 and L3, also for deferred tax assets and liabilities. 20. Crédit Agricole Assurances BS-C1 – Frequency Quarterly diffusion of the BS-C1 template : it is written that this template will be quarterly and exhaustively produced in case “the reconciliation reserve cannot be sufficiently explained from the Please see answer to comment 15.
We would ask for the level 3 guidelines to say, for the avoidance of doubt, that all investment funds should be classified on the Group balance sheet as “investment funds” and not consolidated on a line by line basis, irrespective of the treatment within the statutory accounts. 36. CEA BS-C1 – General A full accounting reconciliation between the Solvency II valuation and statutory accounts valuation columns will be incredibly difficult to achieve, particularly when the statutory accounts valuation is based on local GAAP. Differences between the two columns should be explained to supervisors in a narrative statement rather than requiring a full quantitative reconciliation. The CEA queries whether undertakings will have the choice of substituting local GAAP figures with internal IFRS valuations. For group figures in particular, Solvency II vs. local GAAP differences will be problematic, particularly for the following items: Deferred tax assets/liabilities; Intangible assets; Pension benefit surplus; Property, plant and equipment for own use; Participations; Equities; Derivatives; Statutory balance sheet reporting along with SII balance sheet is important for supervisors to understand, in a standard form, which are the main classifications and valuation differences from statutory to Solvency II data. The same applies to groups. Please see comment n. 1) The reported figures in Statutory column should be the "official" accounting balance independent if national GAAP or IFRS, both for solo and groups.
57. CEA BS-C1 – Groups It may be the case that the scope of entities under consolidated accounts is larger than that of the scope of entities under Solvency II group supervision. A direct comparison between Solvency II and statutory accounting valuation columns will therefore not be possible. For public disclosure, it would mean that the Solvency II balance sheet is misleading and for this reason, we propose not to disclose the statutory accounting valuation column and instead provide a narrative explanation of the differences arising between the two columns. Statutory column will not be subject to public disclosure. 59. German Insurance Association (GDV) BS-C1 – Groups It may be the case that the scope of entities under consolidated accounts is larger than that of the scope of entities under Solvency II group supervision. A direct comparison between Solvency II value and statutory accounts valuation columns will therefore not be possible. For public disclosure, it would mean that the Solvency II balance sheet is misleading and for this reason, we propose not to disclose the statutory accounts valuation column and provide a narrative explanation of the differences arising between the two columns. Please see comment n. 57 60. KPMG BS-C1 – Groups Guidance is required on the consolidation methodology to be applied in preparing a group balance sheet and related disclosures. We expect the systems design and build effort to be greatest for groups and such guidance is key to allow these activities to begin. Particular guidance is required on the following topics: - Treatment of other financial sector subsidiaries in the Group Solvency II balance sheet - Treatment of associates and joint ventures in the Group Solvency II balance sheet The treatment of related undertakings in group solvency calculation is in L2. Additional guidance will be provided in L3.
80. CFO Forum & CRO Forum BS-C1- cell A12 We oppose the inclusion of unit-linked in D1 and therefore all numbers in relation to UL fund assets should be included as one line item in the balance sheet. Noted 81. Danish Insurance Association BS-C1- cell A12 It should be specified whether derivatives attached to Unit-linked contracts with a negative value (from D2O) should be included in the A12-sum. Or if they are to be included in the liabilities in cell L16. Following the approach for A10A that only positive values should be reported in this item, the same approach should be kept for A12. 82. German Insurance Association (GDV) BS-C1- cell A12 This comment applies to A12 – AS12. Confirmation is required that is it no longer required to separately split out assets held to cover linked assets. This is not required by IFRS. Please see comment n. 79 83. The Directorate General Statistics (DG-S) of the E BS-C1- cell A12 The assets held for unit-linked contracts are only reported on an aggregated basis (total). It would be good to have the breakdown by instrument (as for the non-unit linked contracts. The breakdown of assets held for unit-linked contracts would be needed, mainly to analyse insurers’ investment portfolios and their impact on the pricing and liquidity of financial markets. More detailed information will be gained via D1. 84. The Phoenix Group BS-C1- cell A12 Please provide further clarification of the definition of ‘Assets held for index-linked and unit-linked funds’? Is the intention to include certain Insurance products (e.g. Index-linked annuities) where not all Investment risk is borne by the policyholder? All index-linked and funds assets will be reported in cell A12. 85. CEA BS-C1- cell A14 This comment applies to A14 to AS14. For BS-C1 those items will be reported
recoverables are not defined in this context, supervisory guidance and examples would be of help. Should cell A20 (Reinsurance receivables) really be included in the sum showed in this field? It is not in line with reinsurance report J3 cell N1 (Total reinsurance recoverables). 107. RSA Insurance Group plc BS-C1- cell A20 The formula on the face of BS-C1 for cell A16 includes this cell, but the LOG does not state this. It appears that the LOG is correct but the face of the template is wrong –this needs to be clarified. Please see comment n. 104 108. The Phoenix Group BS-C1- cell A20 Should ‘Reinsurance receivables’ be included in the cell – A16? Not consistent with QRT J3 – Total reinsurance recoverables. Please see comment n. 104 110. Afa Sjukförsäkring, AFA Trygghetsförsäkring, AFA L BS-C1- cell A23 Please specify what should be reported in this cell. Definition in LOG. 111. Association of British Insurers (ABI) BS-C1- cell A23 Do intra-group balances have to be split between A23 and A20 to distinguish between those arising from insurance related transactions and other transactions? The Log needs to provide some clarity on where intra-group balances should be captured. Should prepayments and accrued income be included in here or in cell A27? Please see comment n. 112 112. CEA BS-C1- cell A23 This comment applies to BS-C1-cells A23 to AS23; cells A29 to AS29. Further clarification required:
Further guidance should be given on how an “organised and officially recognised market” should be interpreted for participations. Supervisory guidance would be helpful on whether the Solvency II valuation should also be used in Assets – D1. The ITS on valuation guidance on participations and active markets (following IFRS principles). Assets templates are for SII purposes, so SII valuation should be used. 136. German Insurance Association (GDV) BS-C1- cell A6 This comment applies to both A6 and AS6. We assume that “participations” covers participating interests in both related and associated undertakings i.e. both ownership and loans. Further guidance should be given on how an “organised and officially recognised market” should be interpreted for participations. Supervisory guidance would be helpful on whether the Solvency II valuation should also be used in Assets – D1. Please see comment n. 134 Please see comment n. 135 137. KPMG BS-C1- cell A6 It is unclear if this line is only applicable to solo reporting or if groups are also required to present participations in this line. If groups are required to present participations in this line, guidance should be provided on what should be included here. Holdings in related undertakings which are not fully consolidated (“line-by-line” will be
Please see comment n. 141 147. Federation of Finnish Financial Services BS-C1- cell A8 No split should be made between government and corporate bonds – too many details will decrease the overview of the Balance sheet. Noted 148. German Insurance Association (GDV) BS-C1- cell A8 This comment applies to cells A8 – AS8 In the LOGs issued in the informal consultation carried out in summer 2010, the definition of Government bonds was as follows: Government bonds as defined in the CEIOPS L2 advice on structure and design of market risk module (ex-CP 47) for spread risk : bonds issued “by or demonstrably guaranteed by national government of an OECD or EEA state, issued in the currency of the government, or issued by a multilateral development bank as listed in Annex VI, Part 1, Number 4 of the Capital Requirements Directive (2006/48/EC) or issued by an international organisation listed in Annex VI, Part 1, Number 5 of the Capital Requirements Directive (2006/48/EC).” The definition used in this consultation is different from the one above as it does not seem to include … “bonds demonstrably guaranteed by national government…” We propose that the definition of government bonds to be included in the balance sheet should be clarified. Please see comment n. 146
Further clarification required: The condition that these borrowings need to be issued in the currency of the government needs clarification. No split should be made between listed and unlisted – too many details will decrease the overview of the Balance sheet. 149. NFU Mutual BS-C1- cell A8 There is an inconsistency between the analysis of Investment Assets as reported in local GAAP, and that used in SII (certain ‘products’ are reported in specific ways locally but have different placement in SII, mostly relates to Government supported items). Should a reanalysis of existing GAAP reporting therefore be required for SII ? Please see comment n. 35 (on classification) 150. RSA Insurance plc BS-C1- cell A8 It to be clarified, given the link made between this form and Assets-D1, whether accrued interest ought to be included within the valuation here and not separately (i.e. “dirty” prices). Reporting will follow valuation rules. In theis case accrued interest should be included. Further clarification can be found in the L3 valuation guidelines. 151. The Phoenix Group BS-C1- cell A8 Please clarify the definition of govenment bonds. Does this include ‘bonds demonstrably guaranteed by national government’ Please see comment n. 146. 152. CEA BS-C1- cell A8A This comment applies to BS-C1-cells-A8A and AS8A. As it currently stands, the CIC does not seem to adequately distinguish between different types of risk categories, primarily with bonds. Financials and Corporates as well as Covered Bonds are all Noted. The CIC table aims at having a classification by both category of asset and
165. Crédit Agricole Assurances BS-C1- cell AS14 Could you precise elements that can be classified in the account « Other technical provisions » in IFRS? What could these technical provisions from local GAAP be? Should we integrate other specific IFRS provisions (as example: LAT, provisions for insufficient of liabilities…?) Besides, the cell title in the BS-C1 template should be LS14 instead of AS14. Is this assumption correct? In some local GAAP such provisions exist – where undertaking in its internal regulations determines such TPs. Correction made. 166. German Insurance Association (GDV) BS-C1- cell AS14 We why this item appears on both the assets and liabilities side of the balance sheet. For assets, it is entered in the accounting valuation column as “loans and mortgages (except loans on policies”. On the liability side, it is entered in the accounting valuation column as “other technical provisions”. We presume that on the liabilities side, the entry should have the code LS14 however there is no corresponding row to provide feedback or definition in the LOG document. Other technical provisions will cover the equalisation provision and reserve and as such, should only be reported on the liability side of the balance sheet. Correction made – on the liabilities side – LS14. 167. RSA Insurance plc BS-C1- cell AS14 “AS14” shown twice on C1 – it should be clarified that this is an error and that the one on the liability side should actually be LS14. Please see comment n. 166 168. The Directorate General Statistics (DG-S) of the E BS-C1- cell AS14 A breakdown of “mortgages and loans” into household and corporate loans would support also the credit risk analysis. Please see comment n. 88
210. Deloitte Touche Tohmatsu BS-C1- cell AS9D See comment on BS-C1- cell AS9A 211. Association of British Insurers (ABI) BS-C1- cell AS9E Same comment as for D4 (look through), data on underlying investments will be difficult to obtain, particularly where investment funds are managed outside the group. Please see comment n. . 196 212. CFO Forum & CRO Forum BS-C1- cell AS9E As above 213. Deloitte Touche Tohmatsu BS-C1- cell AS9E See comment on BS-C1- cell AS9A 214. Association of British Insurers (ABI) BS-C1- cell AS9F Same comment as for D4 (look through), data on underlying investments will be difficult to obtain, particularly where investment funds are managed outside the group. Please see comment n. 196 215. CEA BS-C1- cell AS9F Clarification would be helpful on whether ‘mixed funds’ would be reported here. Following the definitions in CIC, the categorisation of funds should be based on the main underlying instrument of the fund. This breakdown will now be required for public disclosure purposes only. 216. CFO Forum & CRO Forum BS-C1- cell AS9F As above 217. Crédit Agricole Assurances BS-C1- cell AS9F Detail of the« look-through » of UCITS in Balance Sheet: How should we treat in Balance Sheet a “looked-through” UCITS according to the “other” method (treatment of UCITS as equity / no “look-through”)? In this case, the detail of the “look-through” by asset categories (A9A to A9E) would not be available. Please see comment n. . 196
Should we use the line « Investment funds including other financial assets in invested funds » (A9F in Balance Sheet) to integrate the total amount of UCITS which is also in the Assets-D4 template? Otherwise, which classification method do you suggest? 218. Deloitte Touche Tohmatsu BS-C1- cell AS9F See comment on BS-C1- cell AS9A 219. German Insurance Association (GDV) BS-C1- cell AS9F Clarification would be helpful on whether ‘mixed funds’ would be reported here. Please see comment n. 215 220. Federation of Finnish Financial Services BS-C1- cell L10A Technical Provisions should not be divided between life, non-life and health – too many details will decrease the overview of the Balance sheet. Noted, but not agreed. 221. Federation of Finnish Financial Services BS-C1- cell L11 Technical Provisions should not be divided between life, non-life and health – too many details will decrease the overview of the Balance sheet. Noted, but not agreed. 223. Federation of Finnish Financial Services BS-C1- cell L12 Technical Provisions should not be divided between life, non-life and health – too many details will decrease the overview of the Balance sheet. Noted 225. RSA Insurance plc BS-C1- cell L12 Comment re cell LS14: the face of the template incorrectly refers to “AS14” in this cell. In addition, LS14 log only refers to local GAAP –it should be clarified that, where the statutory accounts are prepared under IFRS, this is a valid reference too. In that case IFRS should be treated as local GAAP. 226. CEA BS-C1- cell L13 This comment applies to BS-C1-cells L13 to LS13.
Further clarification required: Should this include all deposits with reinsurers i.e. not just cash? Cash deposits from reinsurers: The amount of this balance item value might be of minor relevance for some undertakings. Yes. Noted. 227. German Insurance Association (GDV) BS-C1- cell L13 This comment applies to L13 – LS13. Further clarification required: Should this include all deposits with reinsurers i.e. not just cash? Cash deposits from reinsurers: The amount of this balance item value might be of minor relevance for some undertakings. Please see comment n. . 227 228. RSA Insurance Group plc BS-C1- cell L15C Please clarify where intercompany (i.e. same group) insurance receivables are to be placed: L15C or L25. Depending on their character: L15C or L25. 229. CEA BS-C1- cell L15D This comment applies to L15D to LS15D. Regarding the Template BS-C1 cell L15D and the related LOG description, the following problem will result from this approach: In cases when the undertaking issues subordinated debt (which will be considered as equity), reporting only “subordinated liabilities not in BOF”, would result in the amount of the issue being significantly reduced by a deferred tax liability amount. The difference between To calculate deferred taxes each individual asset or liability (including subordinated debt), independent of the issues on which line it is presented in the template, should be
reduced by a deferred tax liability amount. The difference between the Solvency II balance sheet and the tax balance sheet must be considered in the calculation of the deferred taxes in general. This is the result of not being included in the line item subordinated liabilities primarily and therefore the check of the equity requirements have to be fulfilled in the moment of building up the balance sheet. This mechanism be avoided if the subordinated liabilities will be shown in the line item subordinated liabilities in the first step. In a further step (after calculation of deferred taxes) this securities would be adjusted to the equity position. Calculating deferred on subordinated liabilities which are treated as equity must be avoided and have to be clarified in the LOG. 231. CEA BS-C1- cell L16 This comment applies to BS-C1-cells L16 to LS16. Further clarification required: We whether structured notes should be categorised as derivatives, since there is no specific row for structured notes on the liability side? They should be presented in L20-LS20 ‘Financial liabilities other than debts owed to credit institutions’ 232. Danish Insurance Association BS-C1- cell L16 It should be specified whether derivatives attached to Unit-linked contracts with a negative value (from D2O) should be included in the A12-sum. Or if they are to be included in the liabilities in cell L16. Please see comment n. 81 233. German Insurance Association (GDV) BS-C1- cell L16 This comment applies to L16 – LS16. Further clarification required: Please see comment n. 231
253. Association of British Insurers (ABI) BS-C1- cell L22 This information is currently only available on an annual Approximations may be possible at an additional cost but we would propose that pension obligations are only required to be updated annually. Please see comment n. 254 254. CEA BS-C1- cell L22 This comment applies to L22 to LS22. Approximations should be allowed in order to calculate the Solvency II value for pension benefit obligations. A respective guideline should be included in the general reporting requirements. Information on valuation will be in L2 and L3 on valuation. 256. German Insurance Association (GDV) BS-C1- cell L22 This comment applies to L22 – LS22. Approximations should be allowed in order to calculate the Solvency II value for pension benefit obligations. A respective guideline should be included in the general reporting requirements. Please see comment n. 254 257. NFU Mutual BS-C1- cell L22 Pension benefit obligations are only normally calculated annually. We assume either that the latest full review (annual) will suffice, or that estimation can be used on a quarterly basis. Please see comment n. 254 258. Association of British Insurers (ABI) BS-C1- cell L23 We do not agree with the recognition of contingent liabilities in the Solvency II balance sheet, unless recognised for accounting purposes. If contingent liabilities have not been accounted for under IAS37 it is because it is not clear that they actually are liabilities at a balance sheet date. Also, in many instances they would be very difficult to value with any degree of robustness and the value assigned would be very subjective. Narrative disclosure of these would be more appropriate. But we caution against requiring public Please see comment n. 259
302. CEA BS-C1- cell LS22 303. German Insurance Association (GDV) BS-C1- cell LS22 304. RSA Insurance Group plc BS-C1- cell LS25 The L25A definition on the face of the template appears to include sub-totals (as does that for A30 total) – we presume this is an error. The LOG definition for L27 should have “comprising” instead of (misspelled) “complementing”. Noted. Noted. 305. Federation of Finnish Financial Services BS-C1- cell LS4 Technical Provisions should not be divided between life, non-life and health – too many details will decrease the overview of the Balance sheet. Noted 306. Federation of Finnish Financial Services BS-C1- cell LS6B Technical Provisions should not be divided between life, non-life and health – too many details will decrease the overview of the Balance sheet. Noted 308. Federation of Finnish Financial Services BS-C1- cell LS7 Technical Provisions should not be divided between life, non-life and health – too many details will decrease the overview of the Balance sheet. Noted. 310. The Directorate General Statistics (DG-S) of the E BS-C1B – Benefits Please refer to BS-C1 - Benefits 311. Association of British Insurers (ABI) BS-C1B – High, unless appropriate materiality limits are applied (current assumption is only include items included in statutory accounts) 312. CEA BS-C1B – Costs Please refer to BS-C1-Costs, for general comments. Noted.
Further clarification required: Should the collateral held be valued at fair value every quarter? For example, revaluation of the FV of property pledge for a mortgage loan every quarter? The revaluation of property pledged, if any, does not seem practical on a quarterly Additional guidance would be helpful. 360. German Insurance Association (GDV) BS-C1B- cell A17 What is to be disclosed under the items “Assets pledged by reinsurers for ceded technical provisions” and “Assets pledged to cedants for technical provisions (reinsurance accepted)”? SII value of asset pledged, in the first case, of the assets that are pledged by the reinsurer when such agreement exists, under the ceded reinsurance treaty. In the second case it refers to the assets pledged by the reporting undertaking, when it is prescribed under the accepted reinsurance agreement / treaty. Association of British Insurers (ABI) BS-C1B- cell A18 Clarity required in the guidance to define Contingent liabilities not in the SII Balance Sheet as BS-C1 cell L23 defines contingent liabilities as those that are off BS in IFRS but can still be valued. This would capture all Contingent Liabilities to which a value can be assigned. What would therefore appear on C1B? Please see comment n. 362
399. ING Data modelling team BS-C1D – General of Assets on C1D is not equal to total of Assets on C1, A28A (Own shares) and A28B (Amounts due in respect of own fund items or initial fund called up but not yet paid in for) are included in Total of Assets on C1 but not included in the total of assets for Is this on purpose or should BS-C1:A28A and BS-C1:A28B should also be included in the formula of BS-C1D:A7. See above 400. PwC BS-C1D – General Guidance is needed as to how the currency of each type of asset and liability should be determined. This may be particulary relevant for items other than financial instruments and for items, such as equity shares, which are listed on multiple exchanges. If the intention is to derive conclusions about currency matching of assets and liabilities, we do not believe that this information can be assessed by looking at the balance sheet figures of assets and liabilities in isolation. For example there might be currency derivatives contained within the assets that will show greater volatility concerning changes in exchange rates than normal assets. If the intention is to draw conclusions on currency exposures, we would suggest using the respective SCR and risk disclosure and thus currency risk information. Please see comment n. 444 402. RSA Insurance Group plc BS-C1D – General It is not explicitly stated (e.g. in the LOG) how reinsurance is to be treated, especially for multi-risk, multi-territory policies. The same applies to technical provisions. This was a comment made in both summer 2010 and February 2011 and it should be properly considered. Please see comment n. 396.
currency is the same as IFRS with closing rate being used for monetary items and spot rate for non-monetary items. reporting year end should be used (currency rates announced by national central bank) 434. CEA BS-C1D- cell A10 We query whether the item in the LOG should read, “deposits from reinsurers and insurance intermediaries and reinsurance payables”. LOG was corrected to say: , “deposits from reinsurers and insurance, intermediaries and reinsurance payables”. 435. German Insurance Association (GDV) BS-C1D- cell A10 We query whether the item in the LOG should read, “deposits from reinsurers and insurance intermediaries and reinsurance payables”. Please see comment n. 434 436. The Phoenix Group BS-C1D- cell A11 Is this value based on the hedging currency or the issue currency? Please see comment n. 393 437. CEA BS-C1D- cell A13 Please refer to BS-C1- cell L23 for comments on reporting of contingent liabilities. 438. German Insurance Association (GDV) BS-C1D- cell A13 Contingent liabilities’ have to be regarded as ‘Any other liabilities’. Contingent liabilities are reported in cell A13 439. CEA BS-C1D- cell A14 There should be a convergent approach towards categorisation of “any other liabilities”. BS-C1-cell L25 is also titled “any other liabilities” yet EIOPA include additional cells in the formula to calculate this cell. We whether L15D and L26 are “other liabilities” or “financial liabilities”, in which case they would be reported in cell A12 of this template. Noted They are liabilities
445. Danish Insurance Association BS-C1D- cell A3 See BS-C1D A11 comment 446. German Insurance Association (GDV) BS-C1D- cell A3 We assume that for dual listed investments, the undertaking can choose the currency denomination. Further clarification required: Where derivatives are held and these are for example, cross currency basis swaps, how should these be reported? Also, would it not be preferable to report them based on their economic effect so as to show the hedging impact of the transaction? Should Collective Investment Schemes (CIS) be done on a ‘look through’ basis? How should CIS that are not sufficiently transparent be treated, where currency information of the underlying assets is not available or cannot be quantified? Please see comment n. 444 447. London Group BS-C1D- cell A3 How should investment be included – in the currency that the fund is denominated in or by looking-through to the underlying assets and liabilities. If it is on a look-through basis, this will be extremely difficult to do. Please see comment n. 443 448. The Phoenix Group BS-C1D- cell A3 Where derivatives are held and these are for example, cross currency basis swaps, how should these be reported? Also, would it not be preferable to report them based on their economic effect so as to show the hedging impact of the transaction? Please see comment n. 444 449. CEA BS-C1D- cell A4 The LOG states that cell A27A from template BS-C1 should map to this cell, however A27A has since been removed from the balance sheet. The LOG should be updated to reflect this. The LOG was corrected.
458. CEA BS-C1D- cell A6 Please refer to BS-C1-cell A20 for comments on reinsurance receivables. 459. ING Group Data modelling team BS-C1D- cell A6 Formula includes the value from BS-C 1 A20 . However through the inclusion of BS-C1 A20 in the formula for A5A, BS-C1 A20 would already be included in the value of A5A. See also remark on cell A20 in BS-C1. Please see comment n. 456 460. RSA Insurance Group plc BS-C1D- cell A6 See A5A. 461. CEA BS-C1D- cell A7 There should be a convergent approach towards categorisation of “any other assets”. BS-C1-cell A29 is also titled “any other assets” yet EIOPA include additional cells in the formula to calculate this cell. Noted 462. ING Data modelling team BS-C1D- cell A7 According to formula in log file BS-C1 A27 is counted twice: Once in A4 and once in A7. This can not be correct, We assume A27 should be included in A4 and not in A7.Can you confirm that our assumption is correct? A27 of BS-C1 is only in A4 of BS-C1D 463. KPMG BS-C1D- cell A7 For the template to agree with the BS – C1 total assets, this cell should also include A28A Own shares and A28B Amounts due in respect of own fund items or initial fund called up but not yet paid in Please see comment n. 398 464. RSA Insurance Group plc BS-C1D- cell A7 The LOG definition certain assets not included elsewhere, such as A3, A28A and A28B. Without including these, the BS-C1D total will not agree with BS-C1. A3 of BS-C1 is in A4 of BS-C1D. Please see comment n. 398 465. CEA BS-C1D- cell A8 We propose that the risk margin be reported at entity level. Please see comment n. 296 466. German Insurance Association (GDV) BS-C1D- cell A8 Please also refer to comments on A6. Please see comment n. 296