17. AMICE Cover A1A & It would be too burdensome to produce the information requested on Undertaking needs to – Q- Frequency a quarterly basis. Premiums and claims should only be reported on an follow the premiums and annual basis. claims on a more frequent basis 18. Deloitte Touche A1A & See comment on Cover a A1A & Q- Disclosure – Tohmatsu Q- Frequency 19. German Insurance Cover A1A & Quarterly reporting should allow for the use of approximations. – Association (GDV) Q- Frequency For reinsurance especially for non-proportional business, payments Simplifications to be for ceded business are are often accounted for only on a yearly basis. used are the ones to be Quarterly reporting on the reinsurer’s share would be incomplete defined Level 2. therefore an annual frequency for reporting this information should be required. Noted. Here a materiality thereshold could be applied, e.g. if the reinsurance share accounts only for x% of total TP, no quarterly reporting of reinsurance business would be necessary. 21. The Directorate Cover A1A & See comment above for cover- K1 – General Statistics Q- Frequency (DG-S) of the E 22. AMICE Cover A1A & Members raise concerns with regard to the allocation of expenses Please see com. 6 – Q- General between different types of portfolio: difficulties in splitting overhead expenses among products. We strongly suggest that EIOPA allow simplifications for these calculations and/or provide examples. 23. Association of Cover A1A & The majority of the detail for expenses requested for this form would Please see Com. 6 – British Insurers Q- General need to be provided by allocation as this level of data is not held by (ABI) the organisation. Examples are;
17. AMICE Cover – A1A & Q- Frequency It would be too burdensome to produce the information requested on a quarterly basis. Premiums and claims should only be reported on an annual basis. Undertaking needs to follow the premiums and claims on a more frequent basis 18. Deloitte Touche Tohmatsu – A1A & Q- Frequency See comment on Cover a A1A & Q- Disclosure 19. German Insurance Association (GDV) Cover – A1A & Q- Frequency Quarterly reporting should allow for the use of approximations. For reinsurance especially for non-proportional business, payments for ceded business are are often accounted for only on a yearly basis. Quarterly reporting on the reinsurer’s share would be incomplete therefore an annual frequency for reporting this information should be required. Here a materiality thereshold could be applied, e.g. if the reinsurance share accounts only for x% of total TP, no quarterly reporting of reinsurance business would be necessary. Simplifications to be used are the ones to be defined Level 2. Noted. 21. The Directorate General Statistics (DG-S) of the E Cover – A1A & Q- Frequency See comment above for cover- K1 22. AMICE Cover – A1A & Q- General Members raise concerns with regard to the allocation of expenses between different types of portfolio: difficulties in splitting overhead expenses among products. We strongly suggest that EIOPA allow simplifications for these calculations and/or provide examples. Please see com. 6 23. Association of British Insurers (ABI) Cover – A1A & Q- General The majority of the detail for expenses requested for this form would need to be provided by allocation as this level of data is not held by the organisation. Examples are; Please see Com. 6
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