1.32. Once the rules for determining the 50%market coverage reporting sample, we do not see how it serves further the Financial stability purposes to enlarge that population at the discretion of the supervisors. Having regards to our above comments, this guideline should be deleted. 44. IRSG Guideline 8 Under 1.34 fourth and last lines: „threshold stated in Guideline 2… OK the regular reporting requirements of …..” Under 1.35 first line and second last line: „on the basis of the list defined in paragraph 1.34 … will report on the basis of the market share…” 45. IRSG Guideline 9 Under 1.36 third line:”to report on the basis of the market share Note that the market share requirement provided in Guideline 2,…” requirement is no longer applied. 46. Deloitte Guideline 9 We propose that”reasonable time” should be defined, and firms Note that the market share Touche should be given at least three months notice if they are to be requirement is no longer Tohmatsu included within scope for financial stability reporting. applied. 47. Insurance Guideline 9 1.36. The notification by NCAs to undertakings within a „reasonable Note that the market share Europe timeframe”, to report under the market share requirement leaves too requirement is no longer much leeway for NCAs that could end up as a time pressure for the applied. undertaking if the ultimate time allotted to report was short. The timeframe needs therefore to leave at least 3 months for the undertaking. 48. MetLife Guideline 9 The notification to undertakings by NCAs should be time bound, to Note that the market share avoid pressures in case of delays. Given the significant impact on the requirement is no longer reporting process/ calendar of a group, it should allow at least 6 applied. months of lead time from when a notification is made to when reporting is first required for submission. 49. IRSG Guideline 10 Under 1.39 fourth and fifth lines: „ensure that the data reported reflect the best assessment oft he current financial and operational The reference was to condition of the entity and are based…” internal audit, removed in Under 1.39 a): Why is threre a reference to controls and audit? Does guideline. It is expected regular supervisory reporting have to be audited? that the supervisory reporting follows
1.32. Once the rules for determining the 50%market coverage reporting sample, we do not see how it serves further the Financial stability purposes to enlarge that population at the discretion of the supervisors. Having regards to our above comments, this guideline should be deleted. 44. IRSG Guideline 8 Under 1.34 fourth and last lines: „threshold stated in Guideline 2… the regular reporting requirements of …..” Under 1.35 first line and second last line: „on the basis of the list defined in paragraph 1.34 … will report on the basis of the market share…” OK 45. IRSG Guideline 9 Under 1.36 third line:”to report on the basis of the market share requirement provided in Guideline 2,…” Note that the market share requirement is no longer applied. 46. Deloitte Touche Tohmatsu Guideline 9 We propose that”reasonable time” should be defined, and firms should be given at least three months notice if they are to be included within scope for financial stability reporting. Note that the market share requirement is no longer applied. 47. Insurance Europe Guideline 9 1.36. The notification by NCAs to undertakings within a „reasonable timeframe”, to report under the market share requirement leaves too much leeway for NCAs that could end up as a time pressure for the undertaking if the ultimate time allotted to report was short. The timeframe needs therefore to leave at least 3 months for the undertaking. Note that the market share requirement is no longer applied. 48. MetLife Guideline 9 The notification to undertakings by NCAs should be time bound, to avoid pressures in case of delays. Given the significant impact on the reporting process/ calendar of a group, it should allow at least 6 months of lead time from when a notification is made to when reporting is first required for submission. Note that the market share requirement is no longer applied. 49. IRSG Guideline 10 Under 1.39 fourth and fifth lines: „ensure that the data reported reflect the best assessment oft he current financial and operational condition of the entity and are based…” Under 1.39 a): Why is threre a reference to controls and audit? Does regular supervisory reporting have to be audited? The reference was to internal audit, removed in guideline. It is expected that the supervisory reporting follows
Final%20Report%20on%20the%20public%20consultation%20CP-14-045%20Guidelines%20on%20Financial%20Stability%20Reporting.docx