o Indirect claims handling ( related to the claim handling portfolio). - overhead expenses - expenses related to the insurace activity not included in the items presented above. 25. AXERIA Cover A1A & We suggest to the line of business medical insurance into Please note that LoB are – “first € PREVOYANCE Q- General insurance” and Insurance”. defined by Level 2 – “complementary AXERIA IARD - Implementing Measures. SOLUCIA The LOG file was 26. CFO Forum & CRO Cover A1A & We would favour that this definition is switched to define country as – changed to state that: Forum Q- General business is underwritten”. “where Criterion for country: -localization of risk for expense”, “Medical The country definition on this form on localization of risks “depends protection”, “Income (like TP-E1 & F1) and not where business is underwritten (like “Workers’ Country - K1)” is unacceptable. compensation”, “Fire and other damage to property” and “Credit and suretyship” Lines of This continues to be a big problem for countries that sell insurance business; under the Freedom to Provide Service (FPS) agreements and for -country of underwriting Reinsurer. In these cases there is no easily identifiable way to for all other Lines of approximate the location of the risk from central systems nor from business.’ local systems. We would favour that this definition is switched to define country as business is underwritten”. An alternative for “where Please see com. 6 reinsurers would be the location of the cedant. We propose simplification of the template, particularly in relation to expenses .
o Indirect claims handling ( related to the claim handling portfolio). - overhead expenses - expenses related to the insurace activity not included in the items presented above. 25. AXERIA PREVOYANCE – AXERIA IARD - SOLUCIA Cover – A1A & Q- General We suggest to the line of business medical insurance into “first € insurance” and “complementary Insurance”. Please note that LoB are defined by Level 2 Implementing Measures. 26. CFO Forum & CRO Forum Cover – A1A & Q- General We would favour that this definition is switched to define country as “where business is underwritten”. The country definition on this form “depends on localization of risks (like TP-E1 & F1) and not where business is underwritten (like Country - K1)” is unacceptable. This continues to be a big problem for countries that sell insurance under the Freedom to Provide Service (FPS) agreements and for Reinsurer. In these cases there is no easily identifiable way to approximate the location of the risk from central systems nor from local systems. We would favour that this definition is switched to define country as “where business is underwritten”. An alternative for reinsurers would be the location of the cedant. We propose simplification of the template, particularly in relation to expenses . The LOG file was changed to state that: Criterion for country: -localization of risk for “Medical expense”, “Income protection”, “Workers’ compensation”, “Fire and other damage to property” and “Credit and suretyship” Lines of business; -country of underwriting for all other Lines of business.’ Please see com. 6