By excluding salvage and subrogation makes reporting substantially more difficult for most EEA entities. Further clarification required: Please note that this Does this template follow pre IFRS deposit accounting template doesn’t follow reporting, i.e. all claims made, or is just claims made on insurance IFRS accounting but contracts and not investment contracts? Solvency II rules. 78. RSA Insurance Cover A1A- Excluding salvage and subrogation from claims paid (and the whole Please see Com. 33 – Group plc cell E1 form, in fact) seems to be nonsensical the form is missing an – important element of insurance cash inflows. Also, this exclusion makes reporting substantially more difficult for most EEA non-life entities. Salvage and subrogation data are not required to be separated out for the calculation of non-life technical provisions (Article 21bis, November 2011 draft Level 2 text), so these are not data that most non-life undertakings currently hold. Without understanding why such data are being insisted upon (no justification has been provided thus far), it is difficult to suggest an alternative. 79. Thomas Miller & Co Cover A1A- The LOG states that claims paid should be included without taking Please see Com. 33 – Ltd cell E1 account of salvages and subrogations. This seems to be an onerous activity as many insurers do not identify these types of recoveries separately. 80. Association of Cover A1A- Administrative expenses need to be defined in more detail. How do Please see Com. 6 and – British Insurers cell E1A the expenses included under this heading differ to those included as 24 (ABI) expenses and expenses? “overhead” “other” 81. Deloitte Touche Cover A1A- The in expenses paid may be challenging to provide for smaller Please see Com. 6 and – Tohmatsu cell E1A undertakings especially the differentiation between administrative 24 – and overhead costs. Therefore we suggest to provide extra guidance
By excluding salvage and subrogation makes reporting substantially more difficult for most EEA entities. Further clarification required: Does this template follow pre IFRS deposit accounting reporting, i.e. all claims made, or is just claims made on insurance contracts and not investment contracts? Please note that this template doesn’t follow IFRS accounting but Solvency II rules. 78. RSA Insurance Group plc Cover – A1A- cell E1 Excluding salvage and subrogation from claims paid (and the whole form, in fact) seems to be nonsensical – the form is missing an important element of insurance cash inflows. Also, this exclusion makes reporting substantially more difficult for most EEA non-life entities. Salvage and subrogation data are not required to be separated out for the calculation of non-life technical provisions (Article 21bis, November 2011 draft Level 2 text), so these are not data that most non-life undertakings currently hold. Without understanding why such data are being insisted upon (no justification has been provided thus far), it is difficult to suggest an alternative. Please see Com. 33 79. Thomas Miller & Co Ltd Cover – A1A- cell E1 The LOG states that claims paid should be included without taking account of salvages and subrogations. This seems to be an onerous activity as many insurers do not identify these types of recoveries separately. Please see Com. 33 80. Association of British Insurers (ABI) Cover – A1A- cell E1A Administrative expenses need to be defined in more detail. How do the expenses included under this heading differ to those included as “overhead” expenses and “other” expenses? Please see Com. 6 and 24 81. Deloitte Touche Tohmatsu Cover – A1A- cell E1A The in expenses paid may be challenging to provide for smaller undertakings – especially the differentiation between administrative and overhead costs. Therefore we suggest to provide extra guidance Please see Com. 6 and 24
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