sophisticated systems will be required collect data from its original source, store and match it to the various reporting templates. Reporting requirements must be determined well in advance of the entry into force date. Please refer to section 4.7 for GDV comments on the time required for implementation. For the Solvency II balance sheet, additional costs might be incurred to report the balance sheet in a fast close timeframe. 11. XL Group plc BS-C1 Costs Overall, significant IT costs will be incurred in building the systems Noted. – necessary to source, store, validate and report the detailed Please see comment n. 6 inforamtion required for Solvency II Pillar 3 reporting. Additional costs are likely to be incurred to report the Solvency II balance sheet to a fast close timeframe. 12. BS-C1 The publication of a balance sheet” does not seem BS-C1 template is a – “solvency Disclosure appropriate as mutual entities are not listed in the financial markets. central element of In our view, the primarily objective of defining a balance disclosure on financial & “solvency sheet” is the assessment of the amount of eligible own funds. Only solvency position. Such the eligible amount of own funds and major changes made to main template needs to be elements of equity should be publicly disclosed. Other specific comparable. Template elements such as investments should be subject to limited also helps to understand disclosure. information. 13. German Insurance BS-C1 As previously mentioned differences in scope and national Please see comment n. 1 – Association (GDV) Disclosure accounting methodologies and will have a large impact on this template and EIOPA’s requirement to perform a quantitative reconciliation. Only the Solvency II value column should be publically disclosed along with a narrative statement explaining differences that have arisen between the two. This would continue to fulfil EIOPA’s envisaged benefits in terms of market transparency. 14. KPMG BS-C1 The draft level 2 implementing measures require non-insurance The SII BS layout is – Disclosure financial institutions (banking entities, investment firms etc.) to be different than the one
sophisticated systems will be required collect data from its original source, store and match it to the various reporting templates. Reporting requirements must be determined well in advance of the entry into force date. Please refer to section 4.7 for GDV comments on the time required for implementation. For the Solvency II balance sheet, additional costs might be incurred to report the balance sheet in a fast close timeframe. 11. XL Group plc BS-C1 – Costs Overall, significant IT costs will be incurred in building the systems necessary to source, store, validate and report the detailed inforamtion required for Solvency II Pillar 3 reporting. Additional costs are likely to be incurred to report the Solvency II balance sheet to a fast close timeframe. Noted. Please see comment n. 6 12. BS-C1 – Disclosure The publication of a “solvency balance sheet” does not seem appropriate as mutual entities are not listed in the financial markets. In our view, the primarily objective of defining a “solvency balance sheet” is the assessment of the amount of eligible own funds. Only the eligible amount of own funds and major changes made to main elements of equity should be publicly disclosed. Other specific elements such as investments should be subject to limited disclosure. BS-C1 template is a central element of disclosure on financial & solvency position. Such template needs to be comparable. Template also helps to understand information. 13. German Insurance Association (GDV) BS-C1 – Disclosure As previously mentioned differences in scope and national accounting methodologies and will have a large impact on this template and EIOPA’s requirement to perform a quantitative reconciliation. Only the Solvency II value column should be publically disclosed along with a narrative statement explaining differences that have arisen between the two. This would continue to fulfil EIOPA’s envisaged benefits in terms of market transparency. Please see comment n. 1 14. KPMG BS-C1 – Disclosure The draft level 2 implementing measures require non-insurance financial institutions (banking entities, investment firms etc.) to be The SII BS layout is different than the one
Comments_template_QRT_BS_final.docx