To the extent that the reports are identical, the number of FS reports should be reduced and instead reference directly to applicable RSR reports. The data requirements should to the extent possible rely on the SII QRT packages as set out in ITS (CP-14-052 and CP-14-055). This information should in turn be sourced directly from the NSAs as recipients of the RSR QRTs. 10. MetLife General Comment We believe that the unit of reporting should be aligned to Solvency II Agreed, please see new public and private reporting, and this should be explicitly laid out in Guideline 3. the guidelines. 11. This comment was submitted as confidential by the stakeholder. 12. OP Group. General Comment We note that the Guidelines are not clear in the case where the In this case, there would insurance undertakings belong to the group of the mixed financial be no financial stability holding company which is exempted from the Solvency II group reporting for the group. supervision according to Article 213(4 or 5) of the Directive and only However, if the the provisions of the Directive 2002/87/EC (FICOD) are applied in undertaking individually the group level. In this case it is possible that the undertaking reaches the size threshold, belongs also to the insurance or reinsurance group but which is not it should report for reporting according to Solvency II. If this exemption is applied in financial stability purposes Solvency II the same exemption shall be applied also in the Financial since it does not belong to Stability Reporting in order that the undertakings shall not be a group which reports for reporting Solvency II in the level of the individual undertaking but these purposes. Finanacial Stability in the level of the group. Financial Stability Reporting should supplement the Solvency II reporting. If the reporting levels differ there s nothing to be supplemented. 13. RSA General Comment We should like to express our appreciation to EIOPA for having Noted. Insurance produced such an extensive package. The package does provide Group plc much clarification where previously there was little; and it serves to provide a very useful basis to help firms prepare for SII implementation. As per EIOPA’s request, our comments are restricted only to those areas which have seen changes from what was consulted upon in
To the extent that the reports are identical, the number of FS reports should be reduced and instead reference directly to applicable RSR reports. The data requirements should to the extent possible rely on the SII QRT packages as set out in ITS (CP-14-052 and CP-14-055). This information should in turn be sourced directly from the NSAs as recipients of the RSR QRTs. 10. MetLife General Comment We believe that the unit of reporting should be aligned to Solvency II public and private reporting, and this should be explicitly laid out in the guidelines. Agreed, please see new Guideline 3. 11. This comment was submitted as confidential by the stakeholder. 12. OP Group. General Comment We note that the Guidelines are not clear in the case where the insurance undertakings belong to the group of the mixed financial holding company which is exempted from the Solvency II group supervision according to Article 213(4 or 5) of the Directive and only the provisions of the Directive 2002/87/EC (FICOD) are applied in the group level. In this case it is possible that the undertaking belongs also to the insurance or reinsurance group but which is not reporting according to Solvency II. If this exemption is applied in Solvency II the same exemption shall be applied also in the Financial Stability Reporting in order that the undertakings shall not be reporting Solvency II in the level of the individual undertaking but Finanacial Stability in the level of the group. Financial Stability Reporting should supplement the Solvency II reporting. If the reporting levels differ there s nothing to be supplemented. In this case, there would be no financial stability reporting for the group. However, if the undertaking individually reaches the size threshold, it should report for financial stability purposes since it does not belong to a group which reports for these purposes. 13. RSA Insurance Group plc General Comment We should like to express our appreciation to EIOPA for having produced such an extensive package. The package does provide much clarification where previously there was little; and it serves to provide a very useful basis to help firms prepare for SII implementation. As per EIOPA’s request, our comments are restricted only to those areas which have seen changes from what was consulted upon in Noted.
Final%20Report%20on%20the%20public%20consultation%20CP-14-045%20Guidelines%20on%20Financial%20Stability%20Reporting.docx