19. CEA BS-C1 We support EIOPA’s direction in applying a clause to limit quarterly Please see answer to – Frequency reporting of the balance sheet however we believe that quarterly comment 15. reporting should not be required as standard. Reporting of the balance sheet is very much reliant on data from other templates which are not calculated/reported at the same frequency therefore to require quarterly reporting on a systematic basis will be problematic. Valuation rules are to be determined in future L2 and L3, also for deferred It should however be stressed that deferred taxes (assets or tax assets and liabilities. liabilities) would be mechanically modified due to changes in assets and liabilities. The explanation of changes in the reconciliation reserve should be analysed with changes in assets and liabilities net of taxes. For example: if assets increase +10 over one year, with no change to liabilities, for a country where the tax rate is 30% then the impact on the reconciliation would be this case, the “logical” changes in the reconciliation reserve should be considered as by the changes in assets, and the exemption for “explained” quarterly reporting should apply. More clarification on what EIOPA interpret would be “explained” helpful, it may be possible to use a different exemption clause for example, a comparison between the delta of change in technical provisions and assets with the delta of total available own funds. 20. Crédit Agricole BS-C1 Quarterly diffusion of the BS-C1 template : it is written that this Please see answer to – Assurances Frequency template will be quarterly and exhaustively produced in case comment 15. “the reconciliation reserve cannot be sufficiently explained from the
19. CEA BS-C1 – Frequency We support EIOPA’s direction in applying a clause to limit quarterly reporting of the balance sheet however we believe that quarterly reporting should not be required as standard. Reporting of the balance sheet is very much reliant on data from other templates which are not calculated/reported at the same frequency therefore to require quarterly reporting on a systematic basis will be problematic. It should however be stressed that deferred taxes (assets or liabilities) would be mechanically modified due to changes in assets and liabilities. The explanation of changes in the reconciliation reserve should be analysed with changes in assets and liabilities net of taxes. For example: if assets increase +10 over one year, with no change to liabilities, for a country where the tax rate is 30% then the “logical” impact on the reconciliation would be this case, the changes in the reconciliation reserve should be considered as “explained” by the changes in assets, and the exemption for quarterly reporting should apply. More clarification on what EIOPA interpret “explained” would be helpful, it may be possible to use a different exemption clause for example, a comparison between the delta of change in technical provisions and assets with the delta of total available own funds. Please see answer to comment 15. Valuation rules are to be determined in future L2 and L3, also for deferred tax assets and liabilities. 20. Crédit Agricole Assurances BS-C1 – Frequency Quarterly diffusion of the BS-C1 template : it is written that this template will be quarterly and exhaustively produced in case “the reconciliation reserve cannot be sufficiently explained from the Please see answer to comment 15.
Comments_template_QRT_BS_final.docx