instead of the principles EIOPA formulates. EIOPA performance reports will be used as and when EIOPA reveals the purpose of the deviation and issues a set of standards without errors, in line with the stated purpose. Furthermore, this template elicits the following comments: EIOPA should clarify whether this template should be completed on a year to date basis or in a discrete manner Cell C0100 - Net gains and losses: Definition of gains and losses as per LOG guidance is; “The gains and losses are calculated as the difference between selling or maturity value and the value according to article 75 of Directive 2009/138/EC at the end of the prior reporting year end (or, in case of assets acquired during the reporting period, the acquisition value).” This is not in line with the net gains and losses calculation under IFRS and hence, additional effort is required to acquire this information. We ask EIOPA to align net gains and losses calculation with under IFRS to achieve consistency. We believe that the different definition introduces significant complexity into the process and question its real value given that unrealised gains are now also being reported C0100 and C0110: EIOPA must clarify whether loss amounts should be filled out in negative or whether the formula accounts for the signs. C0070 and C0080 Dividends and interest. Should the amounts disclosed for dividends and interest be shown gross or net of tax? Definitions need to be improved - ought to refer to income “receivable” during the year; or income “received and accrued at the period end, less amounts accrued during the previous period.” There are errors in the current version of the templates: o The LOG file still partially refers to cash based reporting.
instead of the principles EIOPA formulates. EIOPA performance reports will be used as and when EIOPA reveals the purpose of the deviation and issues a set of standards without errors, in line with the stated purpose. Furthermore, this template elicits the following comments: EIOPA should clarify whether this template should be completed on a year to date basis or in a discrete manner Cell C0100 - Net gains and losses: Definition of gains and losses as per LOG guidance is; “The gains and losses are calculated as the difference between selling or maturity value and the value according to article 75 of Directive 2009/138/EC at the end of the prior reporting year end (or, in case of assets acquired during the reporting period, the acquisition value).” This is not in line with the net gains and losses calculation under IFRS and hence, additional effort is required to acquire this information. We ask EIOPA to align net gains and losses calculation with under IFRS to achieve consistency. We believe that the different definition introduces significant complexity into the process and question its real value given that unrealised gains are now also being reported C0100 and C0110: EIOPA must clarify whether loss amounts should be filled out in negative or whether the formula accounts for the signs. C0070 and C0080 Dividends and interest. Should the amounts disclosed for dividends and interest be shown gross or net of tax? Definitions need to be improved - ought to refer to income “receivable” during the year; or income “received and accrued at the period end, less amounts accrued during the previous period.” There are errors in the current version of the templates: o The LOG file still partially refers to cash based reporting.
Final%20Report%20on%20the%20public%20consultation%20CP-14-045%20Guidelines%20on%20Financial%20Stability%20Reporting.docx