399. ING Data BS-C1D of Assets on C1D is not equal to total of Assets on C1, A28A See above – modelling team General (Own shares) and A28B (Amounts due in respect of own fund items or initial fund called up but not yet paid in for) are included in Total of Assets on C1 but not included in the total of assets for Is this on purpose or should BS-C1:A28A and BS-C1:A28B should also be included in the formula of BS-C1D:A7. 400. PwC BS-C1D Guidance is needed as to how the currency of each type of asset and – General liability should be determined. This may be particulary relevant for Please see comment n. items other than financial instruments and for items, such as equity 444 shares, which are listed on multiple exchanges. If the intention is to derive conclusions about currency matching of assets and liabilities, we do not believe that this information can be assessed by looking at the balance sheet figures of assets and liabilities in isolation. For example there might be currency derivatives contained within the assets that will show greater volatility concerning changes in exchange rates than normal assets. If the intention is to draw conclusions on currency exposures, we would suggest using the respective SCR and risk disclosure and thus currency risk information. 402. RSA Insurance BS-C1D It is not explicitly stated (e.g. in the LOG) how reinsurance is to be Please see comment n. – Group plc General treated, especially for multi-risk, multi-territory policies. The same 396. applies to technical provisions. This was a comment made in both summer 2010 and February 2011 and it should be properly considered.
399. ING Data modelling team BS-C1D – General of Assets on C1D is not equal to total of Assets on C1, A28A (Own shares) and A28B (Amounts due in respect of own fund items or initial fund called up but not yet paid in for) are included in Total of Assets on C1 but not included in the total of assets for Is this on purpose or should BS-C1:A28A and BS-C1:A28B should also be included in the formula of BS-C1D:A7. See above 400. PwC BS-C1D – General Guidance is needed as to how the currency of each type of asset and liability should be determined. This may be particulary relevant for items other than financial instruments and for items, such as equity shares, which are listed on multiple exchanges. If the intention is to derive conclusions about currency matching of assets and liabilities, we do not believe that this information can be assessed by looking at the balance sheet figures of assets and liabilities in isolation. For example there might be currency derivatives contained within the assets that will show greater volatility concerning changes in exchange rates than normal assets. If the intention is to draw conclusions on currency exposures, we would suggest using the respective SCR and risk disclosure and thus currency risk information. Please see comment n. 444 402. RSA Insurance Group plc BS-C1D – General It is not explicitly stated (e.g. in the LOG) how reinsurance is to be treated, especially for multi-risk, multi-territory policies. The same applies to technical provisions. This was a comment made in both summer 2010 and February 2011 and it should be properly considered. Please see comment n. 396.
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