template will be used for disclosure only annually. 12. European Captive Insurance and Reinsurance Owners – A1A & Q- Disclosure We object to public disclosure of this document for captives as this would release sensitive competitive information. Captives are seeking an exemption from disclosure under article 53 (1). Noted 13. Federation of Finnish Financial Services – A1A & Q- Disclosure We support move towards developing a simplified template for public disclosure however the definitions used must be consistent with IFRS. Not agreed. Data requirements for Solvency purposes are on SII basis. 14. German Insurance Association (GDV) Cover – A1A & Q- Disclosure GDV supports EIOPA’s move towards developing a simplified template for public disclosure however the definitions used must be consistent with IFRS. To disclose similar information with different definitions does not add transparency and could be misleading for readers. We propose to keep definitions in line with IFRS. Please also see our comments on VA templates. Please see Com. 13 15. KPMG Cover – A1A & Q- Disclosure We welcome the simplified content of the publicly disclosed template. Noted. 16. RSA Insurance Group plc – A1A & Q- Disclosure Given the combination of written premiums (not a cashflow), earned premiums (not a SII concept) and claims/expenses paid (cashflow amounts but not in the financial statements), these numbers may simply create confusion, not clarity, amongst the public. We therefore do not support public disclosure. Noted. Both definitions of written and earned premiums will be provided by Level 2 Implementing Measures. The information required on expenses and claims was changed to require only data on accrual basis.
17. AMICE Cover – A1A & Q- Frequency It would be too burdensome to produce the information requested on a quarterly basis. Premiums and claims should only be reported on an annual basis. Undertaking needs to follow the premiums and claims on a more frequent basis 18. Deloitte Touche Tohmatsu – A1A & Q- Frequency See comment on Cover a A1A & Q- Disclosure 19. German Insurance Association (GDV) Cover – A1A & Q- Frequency Quarterly reporting should allow for the use of approximations. For reinsurance especially for non-proportional business, payments for ceded business are are often accounted for only on a yearly basis. Quarterly reporting on the reinsurer’s share would be incomplete therefore an annual frequency for reporting this information should be required. Here a materiality thereshold could be applied, e.g. if the reinsurance share accounts only for x% of total TP, no quarterly reporting of reinsurance business would be necessary. Simplifications to be used are the ones to be defined Level 2. Noted. 21. The Directorate General Statistics (DG-S) of the E Cover – A1A & Q- Frequency See comment above for cover- K1 22. AMICE Cover – A1A & Q- General Members raise concerns with regard to the allocation of expenses between different types of portfolio: difficulties in splitting overhead expenses among products. We strongly suggest that EIOPA allow simplifications for these calculations and/or provide examples. Please see com. 6 23. Association of British Insurers (ABI) Cover – A1A & Q- General The majority of the detail for expenses requested for this form would need to be provided by allocation as this level of data is not held by the organisation. Examples are; Please see Com. 6
By excluding salvage and subrogation makes reporting substantially more difficult for most EEA entities. Further clarification required: Does this template follow pre IFRS deposit accounting reporting, i.e. all claims made, or is just claims made on insurance contracts and not investment contracts? Please note that this template doesn’t follow IFRS accounting but Solvency II rules. 78. RSA Insurance Group plc Cover – A1A- cell E1 Excluding salvage and subrogation from claims paid (and the whole form, in fact) seems to be nonsensical – the form is missing an important element of insurance cash inflows. Also, this exclusion makes reporting substantially more difficult for most EEA non-life entities. Salvage and subrogation data are not required to be separated out for the calculation of non-life technical provisions (Article 21bis, November 2011 draft Level 2 text), so these are not data that most non-life undertakings currently hold. Without understanding why such data are being insisted upon (no justification has been provided thus far), it is difficult to suggest an alternative. Please see Com. 33 79. Thomas Miller & Co Ltd Cover – A1A- cell E1 The LOG states that claims paid should be included without taking account of salvages and subrogations. This seems to be an onerous activity as many insurers do not identify these types of recoveries separately. Please see Com. 33 80. Association of British Insurers (ABI) Cover – A1A- cell E1A Administrative expenses need to be defined in more detail. How do the expenses included under this heading differ to those included as “overhead” expenses and “other” expenses? Please see Com. 6 and 24 81. Deloitte Touche Tohmatsu Cover – A1A- cell E1A The in expenses paid may be challenging to provide for smaller undertakings – especially the differentiation between administrative and overhead costs. Therefore we suggest to provide extra guidance Please see Com. 6 and 24
112. Thomas Miller & Co Ltd Cover – A1A- cell F1B Refer to comments in A1A cell E1A above Noted 113. Deloitte Touche Tohmatsu Cover – A1A- cell F1C The split in expenses paid may be challenging to provide for smaller undertakings. Noted 114. Deloitte Touche Tohmatsu Cover – A1A- cell F1D The split in expenses paid may be challenging to provide for smaller undertakings. Noted 115. Deloitte Touche Tohmatsu Cover – A1A- cell F1E The split in expenses paid may be challenging to provide for smaller undertakings – especially the differentiation between administrative and overhead costs. Noted 116. RSA Insurance plc – A1A- cell F1E See cell E1E. Noted 117. Thomas Miller & Co Ltd – A1A- cell F1E Refer to comments in A1A cell E1A above Noted 118. RSA Insurance Group plc Cover – A1A- cell G1 See E1 Noted 119. CFO Forum & CRO Forum Cover – A1A- cell G1A For Reinsurers: only the net reinsurance information of the administrative expenses is available as it is does not affect the ceded reinsurance. We propose EIOPA allow simplifications to cater for this. The split is required also for reinsurance undertakings. 120. Deloitte Touche Tohmatsu Cover – A1A- cell G1A The split in expenses paid may be challenging to provide for smaller undertakings – especially the differentiation between administrative and overhead costs. Therefore we suggest to provide extra guidance whether this split is required for small and medium-sized undertakings, and if not specify a threshold. Please see Com. 108 121. Federation of Finnish Financial Services Cover – A1A- cell G1A The allocation of expenses for reinsurance reflect the nature of non-proportional lines and therefore the results may be artificial and insconsistent between company’s.
122. Thomas Miller & Co Ltd Cover – A1A- cell G1A Refer to comments in A1A cell E1A above Noted 123. Deloitte Touche Tohmatsu Cover – A1A- cell G1B The split in expenses paid may be challenging to provide for smaller undertakings. 124. Federation of Finnish Financial Services – A1A- cell G1B Comment is only for non-life insurance : The allocation of expenses for reinsurance reflect the nature of non-proportional lines and therefore the results may be artificial and insconsistent between company’s. See comment in E1B. Noted 125. Thomas Miller & Co Ltd – A1A- cell G1B Refer to comments in A1A cell E1A above Noted 126. Deloitte Touche Tohmatsu Cover – A1A- cell G1C The in expenses paid may be challenging to provide for smaller undertakings. 127. Federation of Finnish Financial Services Cover – A1A- cell G1C Comment is only for non-life insurance : The allocation of expenses for reinsurance doesn’t reflect the nature of non-proportional lines and therefore the results may be artificial and insconsistent between company’s. Noted 128. Deloitte Touche Tohmatsu Cover – A1A- cell G1D The split in expenses paid may be challenging to provide for smaller undertakings. Noted 129. Federation of Finnish Financial Services Cover – A1A- cell G1D Comment is only for non-life insurance : The allocation of expenses for reinsurance doesn’t reflect the nature of non-proportional lines and therefore the results may be artificial and insconsistent between company’s. Noted 130. Deloitte Touche Tohmatsu Cover – A1A- cell G1E The in expenses paid may be challenging to provide for smaller undertakings – especially the differentiation between administrative and overhead costs. Noted
158. Royal London Group Cover – A1A- cell L1A This comment applies to all the expenses cells – L1 to P1. The Log refers to expenses ‘paid’. This implies that these shouldbe on a cash basis. This should be changed to an accruals basis as this is the way that expenses are recorded and used by management. This comment applies to all expenses cells L1 to P1. The template asks for expenses gross and net of reinsurance. The Log definition is ‘share ceded to reinsurance’. Expenses are not ceded to reinsurers. The reinsurers’ share of expenses lines should be deleted. The definition of admin expenses is not clear. For example it is not clear what would be included here and not in overheads and It would be much simpler if there was a single category of expenses, as on A1Q. Alternatively there should be fewer categories of expenses, for example : Acquisition costs, investment management costs, costs of servicing business (including claims) and other. Please see Com. 155 159. Association of British Insurers (ABI) Cover – A1A- cell M1A See comment in L1A above. Reinsurers’ share of expenses is meaningless and should be deleted. Please see Com. 155 160. Deloitte Touche Tohmatsu Cover – A1A- cell M1A The split in expenses paid may be challenging to provide for smaller undertakings – especially the differentiation between administrative and overhead costs. Therefore we suggest to provide extra guidance whether this split is required for small and medium-sized undertakings, and if not specify a threshold. Please see Com. 108 161. Royal London Group Cover – A1A- cell M1A See comment in L1A Reinsurers’ share of expenses is meaningless and should be deleted. Please see Com. 155 162. Deloitte Touche Tohmatsu – A1A- cell O1 The split in expenses paid may be challenging to provide for smaller undertakings. Noted
173. Deloitte Touche Tohmatsu Cover – A1A- cell P1 The split in expenses paid may be challenging to provide for smaller undertakings. Noted 174. Royal London Group Cover – A1A- cell P1 See comment in L1A above. Reinsurers’ share of expenses is meaningless and should be deleted. Noted 175. Association of British Insurers (ABI) Cover – A1A- cell P1A See comment in L1A Reinsurers’ share of expenses is meaningless and should be deleted. Noted 176. Deloitte Touche Tohmatsu Cover – A1A- cell P1A The split in expenses paid may be challenging to provide for smaller undertakings. Noted 177. Royal London Group Cover – A1A- cell P1A See comment in L1A above. Reinsurers’ share of expenses is meaningless and should be deleted. 178. Association of British Insurers (ABI) Cover – A1A- cell P1B See comment in L1A Reinsurers’ share of expenses is meaningless and should be deleted. Noted 179. Deloitte Touche Tohmatsu Cover – A1A- cell P1B The split in expenses paid may be challenging to provide for smaller undertakings. Noted 180. Royal London Group Cover – A1A- cell P1B See comment in L1A above. Reinsurers’ share of expenses is meaningless and should be deleted. Noted 181. Association of British Insurers (ABI) Cover – A1A- cell P1C See comment in L1A Reinsurers’ share of expenses is meaningless and should be deleted. Noted 182. Deloitte Touche Tohmatsu Cover – A1A- cell P1C The split in expenses paid may be challenging to provide for smaller undertakings – especially the differentiation between administrative and overhead costs. Therefore we suggest to provide extra guidance whether this split is required for small and medium-sized undertakings, and if not specify a threshold. Please see Com. 108
183. Royal London Group Cover – A1A- cell P1C See comment in L1A above. Reinsurers’ share of expenses is meaningless and should be deleted. 184. Groupe Consultatif Cover – A1Q- cell A19 Splitting by country quarterly might be disproportionate, (especially given Country-K1 is only required annually) EIOPA considers that this is essential data and only required on aggregated level. 186. Thomas Miller & Co Ltd Cover – A1Q- cell A19 to comments in A1A – Cell A19 Noted 187. Groupe Consultatif Cover – A1Q- cell A20 Splitting by country quarterly might be disproportionate, (especially given Country-K1 is only required annually) Please see Com. 184 188. Thomas Miller & Co Ltd Cover – A1Q- cell A20 Refer to comments in A1A – Cell A19 Noted 189. Groupe Consultatif Cover – A1Q- cell A21 Splitting by country quarterly might be disproportionate, (especially given Country-K1 is only required annually) Please see Com. 184 190. Thomas Miller & Co Ltd Cover – A1Q- cell A21 to comments in A1A – Cell A19 Noted 191. Groupe Consultatif Cover – A1Q- cell A22 Splitting by country quarterly might be disproportionate, (especially given Country-K1 is only required annually) Please see Com. 184 192. Thomas Miller & Co Ltd Cover – A1Q- cell A22 Refer to comments in A1A – Cell A19 Noted 193. Groupe Consultatif – A1Q- cell A23 Splitting by country quarterly might be disproportionate, (especially given Country-K1 is only required annually) Please see Com. 184 194. German Insurance Association (GDV) – A1Q- cell B1 See Cover - A1A- cell B1 Noted 196. German Insurance Association (GDV) Cover – A1Q- cell B2 See Cover - A1A- cell B2 Noted
197. German Insurance Association (GDV) Cover – A1Q- cell C1 See - A1A- cell B13 198. German Insurance Association (GDV) Cover – A1Q- cell E1 See Cover - A1A- cell C1 Noted 199. RSA Insurance Group plc Cover – A1Q- cell E1 See A1A above. Noted 200. German Insurance Association (GDV) Cover – A1Q- cell E1Z • What do « expenses paid » represent ? Concept needs to be consistent with the premium concept (i.e. pure cash flows, ultimates vs. P&L view ; see also Country - K1- cell A1). If a P&L perspective is required then the deferrals (e.g. deferred acquisition costs, no cashflows) have to be included as well. Please see Com. 52 201. KPMG Cover – A1Q- cell E1Z See comments for Cover - A1A- cell E1E Noted 202. German Insurance Association (GDV) Cover – A1Q- cell F1 See Cover - A1A- cell E1 Noted 204. German Insurance Association (GDV) Cover – A1Q- cell F1Z See Cover - A1A- cell E1Z Noted 206. German Insurance Association (GDV) – A1Q- cell G1 See Cover - A1A- cell F1 Noted 207. German Insurance Association (GDV) Cover – A1Q- cell G1Z See Cover - A1A- cell E1Z Noted 208. German Insurance Association (GDV) Cover – A1Q- cell I1 Applies to H2G: Why is it not required to deliver expenses split by country ? How should an profitability assessment per country be possible without the expense split ? Please see Com. 132 209. XL Group plc Cover – A1Q- cell I1 It is not clear from the LOG what expenses should be included in the ‘other expenses’ category, Cell H1F. This needs further clarification. Please see Com. 132
It should be clarified that for reinsurers, the breakdown per country applies to the country of the cedent and not the location of risk. 224. CEA Cover-A1A & Q- Groups This template should be manageable at group level however we would suggest removing the split by country (cells A19-A23); at group level this is an unnecessary requirement. We if it is required to eliminate group internal business or if it is sufficient to sum-up all of the subsidiaries within the group. For example: A direct insurer writes EUR premiums externally (“Gross-Direct Business”: EUR 100mn). Of this EUR 100mn 30% is ceded internally of the Group (“Gross -Reinsurance accepted”: EUR 30mn; and “Reinsurer’s share”: EUR -30mn). The screen-shot below shows the aggregation alternative. The advantages being that no sophisticated consolidation process is required and on a net basis, the profit contribution is correct. Please see answer to n. 44 225. CEA Cover-A1A & Q- Materiality We support EIOPA’s initiative to introduce a materiality threshold however we are unable to provide feedback on proposed percentage (90%) within the timeframe of this consultation. Noted 226. CEA Cover-A1A & Q- Purpose Please refer to Cover-A1-General. Noted 227. CEA cell A1 This comment applies to A1 to D1. Noted