It should be clarified that for reinsurers, the breakdown per country applies to the country of the cedent and not the location of risk. 224. CEA Cover-A1A & This template should be manageable at group level however we Please see answer to n. Q- Groups would suggest removing the split by country (cells A19-A23); at 44 group level this is an unnecessary requirement. We if it is required to eliminate group internal business or if it is sufficient to sum-up all of the subsidiaries within the group. For example: A direct insurer writes EUR premiums externally (“Gross-Direct Business”: EUR 100mn). Of this EUR 100mn 30% is ceded internally of the Group (“Gross -Reinsurance accepted”: EUR 30mn; and share”: EUR -30mn). “Reinsurer’s The screen-shot below shows the aggregation alternative. The advantages being that no sophisticated consolidation process is required and on a net basis, the profit contribution is correct. 225. CEA Cover-A1A & We support EIOPA’s initiative to introduce a materiality threshold Noted Q- Materiality however we are unable to provide feedback on proposed percentage (90%) within the timeframe of this consultation. 226. CEA Cover-A1A & Please refer to Cover-A1-General. Noted Q- Purpose 227. CEA cell This comment applies to A1 to D1. A1 Noted
It should be clarified that for reinsurers, the breakdown per country applies to the country of the cedent and not the location of risk. 224. CEA Cover-A1A & Q- Groups This template should be manageable at group level however we would suggest removing the split by country (cells A19-A23); at group level this is an unnecessary requirement. We if it is required to eliminate group internal business or if it is sufficient to sum-up all of the subsidiaries within the group. For example: A direct insurer writes EUR premiums externally (“Gross-Direct Business”: EUR 100mn). Of this EUR 100mn 30% is ceded internally of the Group (“Gross -Reinsurance accepted”: EUR 30mn; and “Reinsurer’s share”: EUR -30mn). The screen-shot below shows the aggregation alternative. The advantages being that no sophisticated consolidation process is required and on a net basis, the profit contribution is correct. Please see answer to n. 44 225. CEA Cover-A1A & Q- Materiality We support EIOPA’s initiative to introduce a materiality threshold however we are unable to provide feedback on proposed percentage (90%) within the timeframe of this consultation. Noted 226. CEA Cover-A1A & Q- Purpose Please refer to Cover-A1-General. Noted 227. CEA cell A1 This comment applies to A1 to D1. Noted
Comments_template_QRT_Cover_final.docx