The limits now provided will make this form more manageable 418. CEA BS-C1D We support EIOPA’s proposal to apply a materiality threshold Please note that no – Materiality however we would like to highlight that the stated example information on excess of (currencies representing up to 90% of both assets and liabilities) assets over liabilities could be inappropriate for some elements of the balance sheet which (nor on BOF) by do not have a currency for example, excess of assets over liabilities. currencies is required in this template. If the assets are valued at 100€ and the technical liabilities and shares at 90€, the remaining 10€ would be considered as part of the reconciliation reserve. 419. Deloitte Touche BS-C1D burden for small and mediumsized insurance undertakings Noted – Tohmatsu Materiality outside the EURO zone which is not related to these entities’ risk profile. 421. German Insurance BS-C1D - – Association (GDV) Materiality 422. Royal London Group BS-C1D The materiality threshold for this template is essential to Noted – Materiality excessive disclosure and associated cost. The suggested limit of 90% of total assets and liabilities is reasonable. 423. RSA Insurance BS-C1D We believe the 90% limit is too high and that in line with existing Noted – – Group plc Materiality Solvency I practice in certain member states 80% should be used – instead. 424. The Directorate BS-C1D The threshold applied would be fine (e.g. with a coverage up to 90% Noted – General Statistics Materiality of currencies) (DG-S) of the E
The limits now provided will make this form more manageable 418. CEA BS-C1D – Materiality We support EIOPA’s proposal to apply a materiality threshold however we would like to highlight that the stated example (currencies representing up to 90% of both assets and liabilities) could be inappropriate for some elements of the balance sheet which do not have a currency for example, excess of assets over liabilities. If the assets are valued at 100€ and the technical liabilities and shares at 90€, the remaining 10€ would be considered as part of the reconciliation reserve. Please note that no information on excess of assets over liabilities (nor on BOF) by currencies is required in this template. 419. Deloitte Touche Tohmatsu BS-C1D – Materiality burden for small and mediumsized insurance undertakings outside the EURO zone which is not related to these entities’ risk profile. Noted 421. German Insurance Association (GDV) BS-C1D – Materiality - 422. Royal London Group BS-C1D – Materiality The materiality threshold for this template is essential to excessive disclosure and associated cost. The suggested limit of 90% of total assets and liabilities is reasonable. Noted 423. RSA Insurance Group plc BS-C1D – Materiality We believe the 90% limit is too high and that – in line with existing Solvency I practice in certain member states – 80% should be used instead. Noted 424. The Directorate General Statistics (DG-S) of the E BS-C1D – Materiality The threshold applied would be fine (e.g. with a coverage up to 90% of currencies) Noted