frequency and adequate timeliness (on a permanent basis) fulfil the ESCB requirements. 1. Balance information The ECB/Eurosystem currently collects timely and high quality monthly or quarterly statistics for large parts of the euro area financial sector (in particular for credit institutions, money market and other investment funds and securitisation vehicles), but avails only of very limited statistical information on the insurance corporations (IC) sector. Accordingly, improved quarterly balance sheet information, both on a solo/non-consolidated basis (for monetary analysis as well as requirements for the production of other ECB statistics) and on a group/consolidated basis (for financial stability analysis) has been highlighted by users as an essential requirement. The balance sheet information should be separately available for different subsectors of ICs (i.e. life insurance, non-life insurance, composites, and The information required includes an instrument breakdown both on the assets and liabilities side, information on original and remaining maturities of the relevant instruments and a breakdown of the geographical residency and institutional sector of the counterparts. Detailed information on the assets held and liabilities issued by ICs is essential, not only in terms of outstanding amounts at the end of a period, but also in terms of transactions which occur between two reporting periods. Information on euro area IC balance sheet positions and transactions can provide important input to both the monetary and economic analyses underpinning the ECB’s monetary policy. ICs are part of the money-holding sector and are thus integral part of the sectoral analysis of monetary developments. By providing investment opportunities and risk diversification, they have a prominent role for the private sector’s composition of wealth. At the same time, they are among the most important providers of long-term funding to credit institutions, non-financial corporations and the public sector. acknowledges that the criteria defined under CP9 to exempt quarterly reporting of BS-C1 was difficult to apply (and impossible for reporting by groups), creating uncertainty on the quarterly requirements. Also, any 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 balance-sheet quarterly without exemptions is the best approach.
additional costs disproportionate to the impact. If supervisors need the reconciliation reserve difference to be explained they could require additional items in the Reconciliation Reserve section of OF-B1Q to explain it, or notes attached to the return. This appears to be covered in the SFCR (Guideline 22(f)) 121. RSA Insurance plc 4.92 Given forms E1Q and F1Q are not applicable to groups, it would appear that the proposed exemption is not available to groups. If that is the intention, we believe that is disproportionate and we should like to understand the reasons for this – unless the financial stability templates proposals have already been anticipated. Further, it appear – once the assets, technical provisions and own funds have been reported – there would be little benefit to this exemption, since nearly all the work required to produce a balance sheet will have been done anyway. It is also unclear if the quarterly QRTs will actually help explain the quarterly reconciliation reserve movement required under paragraph 4.90. Finally, the conditions are met only when reconciliation reserve is explained “sufficiently” by these other templates – there is an implicit materiality threshold to be applied, i.e. “sufficiently” needs to be clearly defined. The proposed exemption would therefore appear to yield any benefit only in a very limited number of circumstances. Noted.See comment 111 122. The Directorate General Statistics (DG-S) of the E 4.92 The ECB/Eurosystem currently collects timely and high quality monthly or quarterly statistics for large parts of the euro area financial sector but avails only of very limited statistical information on the insurance corporations (IC) sector. Accordingly, improved and detailed quarterly balance sheet information, both on a solo/non-consolidated basis and on a group/consolidated basis has been highlighted by users as an essential requirement. Therefore, template BS-C1 is key for ECB purposes, for information that cannot be derived from quarterly reporting of detailed See comment 111
173. Federation of Finnish Financial Services 4.130 We agree with the EIOPA’s proposal. Noted. See comment 171. 174. FEE 4.131 We that option 2 (only qualitative narrative for RC with figures included) best reflects objectives described in section 3 of the Impact Assessment. Narrative reporting should contain: - the nature of the risk concentration (single counterparty, sector, underlying risks, country …); - the measure used to quantify such exposure : assets, liabilities, sheet commitments, capital at risk, number of claims… - the rationale used to determine what is considered by undertakings to be an “important exposure”. Noted. See comment 171. See also comments template on RC 176. Groupe Consultatif 4.131 We agree that qualitiative reporting with figures would better meet the objectives. The data required in the current template is not clear (see comments on template). The figures required could be information such as that included in the helper tab for QIS5 for market concentration risk combined with references to the reinsurance templates. Noted. See comment 171. See also comments template on RC 177. IUA (INTERNATIONAL UNDERWRITING ASSOCIATION) 4.131 Risk concentration We agree that the option for only qualitative narrative for risk concentration would be more meaningful and effective. Noted. See comment 171. See also comments template on RC 178. RSA Insurance Group plc 4.131 We agree with EIOPA: the current proposed form duplicates, in part, reporting for assets (D series) and reinsurance (e.g. J3). There is no new information being reported here in these areas, so these elements should be withdrawn at the very least. Further, the proposed requirements for the SFCR and RSR already include disclosures on risk concentrations, for each of the major types of risk. Such Noted. See comment 171. See also comments template on RC