112. Thomas Miller & Co Cover A1A- Refer to comments in A1A cell E1A above Noted – Ltd cell F1B 113. Deloitte Touche Cover A1A- The split in expenses paid may be challenging to provide for smaller Noted – Tohmatsu cell F1C undertakings. 114. Deloitte Touche Cover A1A- The split in expenses paid may be challenging to provide for smaller Noted – Tohmatsu cell F1D undertakings. 115. Deloitte Touche Cover A1A- The split in expenses paid may be challenging to provide for smaller Noted – Tohmatsu cell F1E undertakings especially the differentiation between administrative – and overhead costs. 116. RSA Insurance A1A- See cell E1E. Noted – plc cell F1E 117. Thomas Miller & Co A1A- Refer to comments in A1A cell E1A above Noted – Ltd cell F1E 118. RSA Insurance Cover A1A- See E1 Noted – Group plc cell G1 119. CFO Forum & CRO Cover A1A- For Reinsurers: only the net reinsurance information of the The split is required also – Forum cell G1A administrative expenses is available as it is does not affect the ceded for reinsurance reinsurance. We propose EIOPA allow simplifications to cater for this. undertakings. 120. Deloitte Touche Cover A1A- The split in expenses paid may be challenging to provide for smaller Please see Com. 108 – Tohmatsu cell G1A undertakings especially the differentiation between administrative – and overhead costs. Therefore we suggest to provide extra guidance whether this split is required for small and medium-sized undertakings, and if not specify a threshold. 121. Federation of Cover A1A- The allocation of expenses for reinsurance reflect the nature of – Finnish Financial cell G1A non-proportional lines and therefore the results may be artificial and Services insconsistent between company’s.
112. Thomas Miller & Co Ltd Cover – A1A- cell F1B Refer to comments in A1A cell E1A above Noted 113. Deloitte Touche Tohmatsu Cover – A1A- cell F1C The split in expenses paid may be challenging to provide for smaller undertakings. Noted 114. Deloitte Touche Tohmatsu Cover – A1A- cell F1D The split in expenses paid may be challenging to provide for smaller undertakings. Noted 115. Deloitte Touche Tohmatsu Cover – A1A- cell F1E The split in expenses paid may be challenging to provide for smaller undertakings – especially the differentiation between administrative and overhead costs. Noted 116. RSA Insurance plc – A1A- cell F1E See cell E1E. Noted 117. Thomas Miller & Co Ltd – A1A- cell F1E Refer to comments in A1A cell E1A above Noted 118. RSA Insurance Group plc Cover – A1A- cell G1 See E1 Noted 119. CFO Forum & CRO Forum Cover – A1A- cell G1A For Reinsurers: only the net reinsurance information of the administrative expenses is available as it is does not affect the ceded reinsurance. We propose EIOPA allow simplifications to cater for this. The split is required also for reinsurance undertakings. 120. Deloitte Touche Tohmatsu Cover – A1A- cell G1A The split in expenses paid may be challenging to provide for smaller undertakings – especially the differentiation between administrative and overhead costs. Therefore we suggest to provide extra guidance whether this split is required for small and medium-sized undertakings, and if not specify a threshold. Please see Com. 108 121. Federation of Finnish Financial Services Cover – A1A- cell G1A The allocation of expenses for reinsurance reflect the nature of non-proportional lines and therefore the results may be artificial and insconsistent between company’s.
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