163. Deloitte Touche A1A- The split in expenses paid may be challenging to provide for smaller Noted – Tohmatsu cell O1A undertakings. 164. Association of Cover A1A- The log definition of expenses would seem to only include Please see Com. 93 – ‘acquisition’ British Insurers cell O1B commission and sales staff costs. Should other costs related to (ABI) writing new business, e.g. underwriting, be under admin expenses? 165. Deloitte Touche Cover A1A- The in expenses paid may be challenging to provide for smaller – Tohmatsu cell O1B undertakings. 166. Royal London Cover A1A- The log definition of expenses would seem to only include Please see Com. 93 – ‘acquisition’ Group cell O1B commission and sales staff costs. Should other costs related to writing new business, eg underwriting, be under admin expenses ? 167. Association of Cover A1A- The log definition states that this includes overheads incurred in Please see Com. 24 – British Insurers cell O1C servicing business. Does this mean direct costs for servicing business (ABI) are in admin expenses? We do not believe that this split provides useful or meaningful information. 168. Deloitte Touche Cover A1A- The in expenses paid may be challenging to provide for smaller Please see Com. 108 – Tohmatsu cell O1C 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. 169. German Insurance A1A- more precise definition loss statement items is meant Please see Com. 24 – Association (GDV) cell O1C 171. London Group A1A- The log definition states that this includes overheads incurred in Please see Com. 24 – cell O1C servicing business. Does this mean direct costs for servicing business are in admin expenses. We do not believe that this split provides useful or meaningful information. 172. Association of Cover A1A- See comment in L1A above. Reinsurers’ share of expenses is Noted – British Insurers cell P1 meaningless and should be deleted. (ABI)
163. Deloitte Touche Tohmatsu – A1A- cell O1A The split in expenses paid may be challenging to provide for smaller undertakings. Noted 164. Association of British Insurers (ABI) Cover – A1A- cell O1B The log definition of ‘acquisition’ expenses would seem to only include commission and sales staff costs. Should other costs related to writing new business, e.g. underwriting, be under admin expenses? Please see Com. 93 165. Deloitte Touche Tohmatsu Cover – A1A- cell O1B The in expenses paid may be challenging to provide for smaller undertakings. 166. Royal London Group Cover – A1A- cell O1B The log definition of ‘acquisition’ expenses would seem to only include commission and sales staff costs. Should other costs related to writing new business, eg underwriting, be under admin expenses ? Please see Com. 93 167. Association of British Insurers (ABI) Cover – A1A- cell O1C The log definition states that this includes overheads incurred in servicing business. Does this mean direct costs for servicing business are in admin expenses? We do not believe that this split provides useful or meaningful information. Please see Com. 24 168. Deloitte Touche Tohmatsu Cover – A1A- cell O1C 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 whether this split is required for small and medium-sized undertakings, and if not specify a threshold. Please see Com. 108 169. German Insurance Association (GDV) – A1A- cell O1C more precise definition loss statement items is meant Please see Com. 24 171. London Group – A1A- cell O1C The log definition states that this includes overheads incurred in servicing business. Does this mean direct costs for servicing business are in admin expenses. We do not believe that this split provides useful or meaningful information. Please see Com. 24 172. Association of British Insurers (ABI) Cover – A1A- cell P1 See comment in L1A above. Reinsurers’ share of expenses is meaningless and should be deleted. Noted