We would ask for the level 3 guidelines to say, for the avoidance of doubt, that all investment funds should be classified on the Group balance sheet as funds” and not consolidated on a line “investment by line basis, irrespective of the treatment within the statutory accounts. 36. CEA BS-C1 A full accounting reconciliation between the Solvency II valuation Statutory balance sheet – General and statutory accounts valuation columns will be incredibly difficult reporting along with SII to achieve, particularly when the statutory accounts valuation is balance sheet is based on local GAAP. Differences between the two columns should important for supervisors be explained to supervisors in a narrative statement rather than to understand, in a requiring a full quantitative reconciliation. standard form, which are the main classifications and valuation differences The CEA queries whether undertakings will have the choice of from statutory to substituting local GAAP figures with internal IFRS valuations. For Solvency II data. The group figures in particular, Solvency II vs. local GAAP differences will same applies to groups. be problematic, particularly for the following items: Please see comment n. 1) The reported figures in Deferred tax assets/liabilities; Statutory column should Intangible assets; be the "official" accounting balance Pension benefit surplus; independent if national Property, plant and equipment for own use; GAAP or IFRS, both for solo and groups. Participations; Equities; Derivatives;
We would ask for the level 3 guidelines to say, for the avoidance of doubt, that all investment funds should be classified on the Group balance sheet as “investment funds” and not consolidated on a line by line basis, irrespective of the treatment within the statutory accounts. 36. CEA BS-C1 – General A full accounting reconciliation between the Solvency II valuation and statutory accounts valuation columns will be incredibly difficult to achieve, particularly when the statutory accounts valuation is based on local GAAP. Differences between the two columns should be explained to supervisors in a narrative statement rather than requiring a full quantitative reconciliation. The CEA queries whether undertakings will have the choice of substituting local GAAP figures with internal IFRS valuations. For group figures in particular, Solvency II vs. local GAAP differences will be problematic, particularly for the following items: Deferred tax assets/liabilities; Intangible assets; Pension benefit surplus; Property, plant and equipment for own use; Participations; Equities; Derivatives; Statutory balance sheet reporting along with SII balance sheet is important for supervisors to understand, in a standard form, which are the main classifications and valuation differences from statutory to Solvency II data. The same applies to groups. Please see comment n. 1) The reported figures in Statutory column should be the "official" accounting balance independent if national GAAP or IFRS, both for solo and groups.
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