(via negative or positive IBNER). If such actuarial adjustment is to be EIOPA still believes that included in the numbers, this may prove both onerous and the option chosen for the ‘case-by-case’ difficult to achieve, especially on TP-E6. public consultation is the one that contributes to the objectives stated in the impact assessment document. 100. AMICE 4.73 Noted. We are in favour of Option 1. We oppose any requirement to report on the Please see comment 99. number of outstanding claims for the following reasons: 1) The best estimate of technical provisions is mainly driven by paid claims and not by outstanding reserves (with some exceptions such as “peak claims”). 2) Outstanding claims amounts are not easily comparable to Best estimates triangles as the latter include IBNR and are computed using actuarial methodologies and expert judgement, and in some cases they can differ by a great deal. 3) Reinsurance treaties can not be directly applied to outstanding claims (a except XS treaties per but are applied at other levels of aggregation and on a best estimate basis. 101. RSA Insurance 4.77 We do not agree with this conclusion please see 4.78 below. Noted. Please see – Group plc comment 99.
(via negative or positive IBNER). If such actuarial adjustment is to be included in the ‘case-by-case’ numbers, this may prove both onerous and difficult to achieve, especially on TP-E6. EIOPA still believes that the option chosen for the public consultation is the one that contributes to the objectives stated in the impact assessment document. 100. AMICE 4.73 We are in favour of Option 1. We oppose any requirement to report on the number of outstanding claims for the following reasons: 1) The best estimate of technical provisions is mainly driven by paid claims and not by outstanding reserves (with some exceptions such as “peak claims”). 2) Outstanding claims amounts are not easily comparable to Best estimates triangles as the latter include IBNR and are computed using actuarial methodologies and expert judgement, and in some cases they can differ by a great deal. 3) Reinsurance treaties can not be directly applied to outstanding claims (a except XS treaties per but are applied at other levels of aggregation and on a best estimate basis. Noted. Please see comment 99. 101. RSA Insurance Group plc 4.77 We do not agree with this conclusion – please see 4.78 below. Noted. Please see comment 99.