appropriate internal Under 1.39 d): „relevant national supervisory authority” governance. Under 1.41 last line: „improve business processes to reduce over time recurring discrepancies…” Under 1.41 last line: „regular supervisory reporting on the basis of Directive 2009/138/EC.” 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 11) 50. Deloitte Guideline 10 Paragraph 1.39 states that simplifications employed in the Agreed. Touche preparation of data for reporting according to the guidelines should Tohmatsu be employed consistently over time, yet this appears somewhat inconsistent with the guidance of 1.41 in that undertakings should strive to improve business processes over time so as to reduce recurring discrepancies between FST and QRT reporting. Paragaph 1.39 should be amended to acknowledge that changes in simplifications are allowed when they are to satisfy the requirements of other guidelines. 51. Federation of Guideline 10 We wonder if there is any need to explain the simplifications used To balance the views of European under a best effort approach in qualitative terms and not only on different stakeholders, the Accountants request of the NSA (see also GL 11) text is kept unchanged. (FEE) 52. GDV Guideline 10 The introduction of the best-effort principle to provide information is Noted. appreciated. 53. Institute and Guideline 10 We note that much of the information required for financial stability Noted. Faculty of reporting is an output for ‘normal’ supervisory reporting. However, Actuaries the need to produce financial stability metrics on a best efforts basis in advance of supervisory reporting will lead to some duplication of effort. Financial stability data inputs and results will also be provisional, to an extent. Given this and the purpose of its collection, we suggest that the financial stability data / results should be confidential, and
Under 1.39 d): „relevant national supervisory authority” Under 1.41 last line: „improve business processes to reduce over time recurring discrepancies…” Under 1.41 last line: „regular supervisory reporting on the basis of Directive 2009/138/EC.” 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 11) appropriate internal governance. 50. Deloitte Touche Tohmatsu Guideline 10 Paragraph 1.39 states that simplifications employed in the preparation of data for reporting according to the guidelines should be employed consistently over time, yet this appears somewhat inconsistent with the guidance of 1.41 in that undertakings should strive to improve business processes over time so as to reduce recurring discrepancies between FST and QRT reporting. Paragaph 1.39 should be amended to acknowledge that changes in simplifications are allowed when they are to satisfy the requirements of other guidelines. Agreed. 51. Federation of European Accountants (FEE) Guideline 10 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 11) To balance the views of different stakeholders, the text is kept unchanged. 52. GDV Guideline 10 The introduction of the best-effort principle to provide information is appreciated. Noted. 53. Institute and Faculty of Actuaries Guideline 10 We note that much of the information required for financial stability reporting is an output for ‘normal’ supervisory reporting. However, the need to produce financial stability metrics on a best efforts basis in advance of supervisory reporting will lead to some duplication of effort. Financial stability data inputs and results will also be provisional, to an extent. Given this and the purpose of its collection, we suggest that the financial stability data / results should be confidential, and Noted.