therefore not be made public. 54. Investment & Guideline 10 Paragraph 1.39 states that simplifications employed in the Please see answer to Life Assurance preparation of data for reporting should remain consistent over time, comment 50. Group (ILAG) yet this appears somewhat inconsistent with the guidance of 1.41 in that improvements in process should be made over time so as to reduce discrepancies between FST and QRT reporting. We feel that paragaph 1.39 should be amended to acknowledge that changes in simplifications are permitted when they are to satisfy the requirements of other guidelines. 55. MetLife Guideline 10 Further guidance should be included, in the context of a group with In order to allow numerous non-significant subsidiaries, and to what extent undertakings to make the simplification would be appropriate. most useful simplifications in their case, the best effort principle is kept at relatively high level. 56. IRSG Guideline 11 Under 1.42 third and fourth lines: „regular supervisory reporting on See answer to comment the basis of …However, the relevant national supervisory authority…” 51 We wonder if there is no need to explain the simplifications used under a best effort approach in qualitative terms anyway and not only on request of the NSA (see also GL 10). 57. Federation of Guideline 11 We wonder if there is any need to explain the simplifications used Please see answer to European under a best effort approach in qualitative terms and not only on comment 51. Accountants request of the NSA (see also GL 10). (FEE) 58. GDV Guideline 11 In light of the fact that fulfilling reporting requirements under Agree, the final Guideline Solvency II already poses a heavy administrative burden on reflects a balanced insurance companies, financial stability reporting and SII-reporting approach between burden should be streamlined and divergent reporting requirements should and EIOPA responsibilities, be avoided. and includes increased consistency with prudential reporting. 59. Insurance Guideline 11 There should be no requirement to explain the difference between See answer to comment Europe information submitted for financial stability purposes and regular 51.
therefore not be made public. 54. Investment & Life Assurance Group (ILAG) Guideline 10 Paragraph 1.39 states that simplifications employed in the preparation of data for reporting should remain consistent over time, yet this appears somewhat inconsistent with the guidance of 1.41 in that improvements in process should be made over time so as to reduce discrepancies between FST and QRT reporting. We feel that paragaph 1.39 should be amended to acknowledge that changes in simplifications are permitted when they are to satisfy the requirements of other guidelines. Please see answer to comment 50. 55. MetLife Guideline 10 Further guidance should be included, in the context of a group with numerous non-significant subsidiaries, and to what extent simplification would be appropriate. In order to allow undertakings to make the most useful simplifications in their case, the best effort principle is kept at relatively high level. 56. IRSG Guideline 11 Under 1.42 third and fourth lines: „regular supervisory reporting on the basis of …However, the relevant national supervisory authority…” We wonder if there is no need to explain the simplifications used under a best effort approach in qualitative terms anyway and not only on request of the NSA (see also GL 10). See answer to comment 51 57. Federation of European Accountants (FEE) Guideline 11 We wonder if there is any need to explain the simplifications used under a best effort approach in qualitative terms and not only on request of the NSA (see also GL 10). Please see answer to comment 51. 58. GDV Guideline 11 In light of the fact that fulfilling reporting requirements under Solvency II already poses a heavy administrative burden on insurance companies, financial stability reporting and SII-reporting should be streamlined and divergent reporting requirements should be avoided. Agree, the final Guideline reflects a balanced approach between burden and EIOPA responsibilities, and includes increased consistency with prudential reporting. 59. Insurance Europe Guideline 11 There should be no requirement to explain the difference between information submitted for financial stability purposes and regular See answer to comment 51.
Final%20Report%20on%20the%20public%20consultation%20CP-14-045%20Guidelines%20on%20Financial%20Stability%20Reporting.docx