number and others do not. See for example Guideline 13 which relates to group but the view refers to all templates. 81. IRSG Guideline 17 Under 1.53 introductory parabraph: „the following information”. OK Delete the words „listed in the following paragraphs” 82. Institute and Guideline 17 We suggest EIOPA reconsiders whether the level of detail required See comment 1. Faculty of for the items listed in Guidelines 13-18 is appropriate. Actuaries 83. Insurance Guideline 17 Similarly to GL 14, we ask for more clarity on the concept of Please see answer to Europe reports – are they considered an own separate set of comment 70. reporting templates, or part of the quarterly package. This should be closer defined as it affects amongst other things the focus of developing new templates/sourcing the requirements for data 84. IRSG Guideline 18 Under 1.54 introductory paragraph: „the following information”. OK or no longer applicable. Delete the words „listed in the following paragraphs” Under 1.54 a) and b): delete the words „detailing the information” The quarterly reporting Under 1.54 c: What is meant by „all collective investments differs in cases where the undertakings held”? data required is already reported earlier for Under 1.54 e)i: „The information shall be reported… with maturity prudential purposes (for dates falling after the reference date represents …” individuals). Given that individual undertakings do only have to report financial stability information if they are not part of a group being obliged to perform financial stability reporting we do not understand why the quarterly reporting required here is not identical to the group requirements in GL 15. 85. Actuarial Guideline 18 Similarly to our comment on guideline 15, do all reporting EIOPA does not expect Association of exemptions that apply to the main QRTs also apply to financial that undertakings captured Europe (AAE) stability reporting? We accept that this issue may not arise in by the FS threshold are practice as smaller firms are unlikely to be in scope for solo financial exempted. However, stability reporting. please see para. 1.18. See also answer to comment 73. 86. Actuarial Guideline 18 Similarly to our comment on guideline 15, do all reporting Please see also answer to
number and others do not. See for example Guideline 13 which relates to group but the view refers to all templates. 81. IRSG Guideline 17 Under 1.53 introductory parabraph: „the following information”. Delete the words „listed in the following paragraphs” OK 82. Institute and Faculty of Actuaries Guideline 17 We suggest EIOPA reconsiders whether the level of detail required for the items listed in Guidelines 13-18 is appropriate. See comment 1. 83. Insurance Europe Guideline 17 Similarly to GL 14, we ask for more clarity on the concept of reports – are they considered an own separate set of reporting templates, or part of the quarterly package. This should be closer defined as it affects amongst other things the focus of developing new templates/sourcing the requirements for data Please see answer to comment 70. 84. IRSG Guideline 18 Under 1.54 introductory paragraph: „the following information”. Delete the words „listed in the following paragraphs” Under 1.54 a) and b): delete the words „detailing the information” Under 1.54 c: What is meant by „all collective investments undertakings held”? Under 1.54 e)i: „The information shall be reported… with maturity dates falling after the reference date represents …” Given that individual undertakings do only have to report financial stability information if they are not part of a group being obliged to perform financial stability reporting we do not understand why the quarterly reporting required here is not identical to the group requirements in GL 15. OK or no longer applicable. The quarterly reporting differs in cases where the data required is already reported earlier for prudential purposes (for individuals). 85. Actuarial Association of Europe (AAE) Guideline 18 Similarly to our comment on guideline 15, do all reporting exemptions that apply to the main QRTs also apply to financial stability reporting? We accept that this issue may not arise in practice as smaller firms are unlikely to be in scope for solo financial stability reporting. EIOPA does not expect that undertakings captured by the FS threshold are exempted. However, please see para. 1.18. See also answer to comment 73. 86. Actuarial Guideline 18 Similarly to our comment on guideline 15, do all reporting Please see also answer to