template will be used for disclosure only annually. 12. European Captive A1A & We object to public disclosure of this document for captives as this Noted – Insurance and Q- Disclosure would release sensitive competitive information. Captives are Reinsurance seeking an exemption from disclosure under article 53 (1). Owners 13. Federation of A1A & We support move towards developing a simplified template for Not agreed. Data – Finnish Financial Q- Disclosure public disclosure however the definitions used must be consistent requirements for Services with IFRS. Solvency purposes are on SII basis. 14. German Insurance Cover A1A & GDV supports EIOPA’s move towards developing a simplified template Please see Com. 13 – Association (GDV) Q- Disclosure for public disclosure however the definitions used must be consistent with IFRS. To disclose similar information with different definitions does not add transparency and could be misleading for readers. We propose to keep definitions in line with IFRS. Please also see our comments on VA templates. 15. KPMG Cover A1A & We welcome the simplified content of the publicly disclosed template. Noted. – Q- Disclosure 16. RSA Insurance A1A & Given the combination of written premiums (not a cashflow), earned Noted. Both definitions – Group plc Q- Disclosure premiums (not a SII concept) and claims/expenses paid (cashflow of written and earned amounts but not in the financial statements), these numbers may premiums will be simply create confusion, not clarity, amongst the public. We therefore provided by Level 2 do not support public disclosure. Implementing Measures. The information required on expenses and claims was changed to require only data on accrual basis.
template will be used for disclosure only annually. 12. European Captive Insurance and Reinsurance Owners – A1A & Q- Disclosure We object to public disclosure of this document for captives as this would release sensitive competitive information. Captives are seeking an exemption from disclosure under article 53 (1). Noted 13. Federation of Finnish Financial Services – A1A & Q- Disclosure We support move towards developing a simplified template for public disclosure however the definitions used must be consistent with IFRS. Not agreed. Data requirements for Solvency purposes are on SII basis. 14. German Insurance Association (GDV) Cover – A1A & Q- Disclosure GDV supports EIOPA’s move towards developing a simplified template for public disclosure however the definitions used must be consistent with IFRS. To disclose similar information with different definitions does not add transparency and could be misleading for readers. We propose to keep definitions in line with IFRS. Please also see our comments on VA templates. Please see Com. 13 15. KPMG Cover – A1A & Q- Disclosure We welcome the simplified content of the publicly disclosed template. Noted. 16. RSA Insurance Group plc – A1A & Q- Disclosure Given the combination of written premiums (not a cashflow), earned premiums (not a SII concept) and claims/expenses paid (cashflow amounts but not in the financial statements), these numbers may simply create confusion, not clarity, amongst the public. We therefore do not support public disclosure. Noted. Both definitions of written and earned premiums will be provided by Level 2 Implementing Measures. The information required on expenses and claims was changed to require only data on accrual basis.
Comments_template_QRT_Cover_final.docx