173. Federation of 4.130 We agree with the EIOPA’s proposal. Noted. See comment 171. Finnish Financial Services 174. FEE 4.131 We that option 2 (only qualitative narrative for RC with figures included) Noted. See comment 171. best reflects objectives described in section 3 of the Impact Assessment. See also comments Narrative reporting should contain: template on RC - the nature of the risk concentration (single counterparty, sector, underlying risks, country …); - the measure used to quantify such exposure : assets, liabilities, sheet commitments, capital at risk, number of claims… - the rationale used to determine what is considered by undertakings to be an exposure”. “important 176. Groupe Consultatif 4.131 We agree that qualitiative reporting with figures would better meet the Noted. See comment 171. objectives. The data required in the current template is not clear (see See also comments comments on template). The figures required could be information such as template on RC that included in the helper tab for QIS5 for market concentration risk combined with references to the reinsurance templates. 177. IUA 4.131 Risk concentration We agree that the option for only qualitative narrative for Noted. See comment 171. (INTERNATIONAL risk concentration would be more meaningful and effective. See also comments UNDERWRITING template on RC ASSOCIATION) 178. RSA Insurance 4.131 We agree with EIOPA: the current proposed form duplicates, in part, Noted. See comment 171. Group plc reporting for assets (D series) and reinsurance (e.g. J3). There is no See also comments new information being reported here in these areas, so these elements template on RC should be withdrawn at the very least. Further, the proposed requirements for the SFCR and RSR already include disclosures on risk concentrations, for each of the major types of risk. Such
173. Federation of Finnish Financial Services 4.130 We agree with the EIOPA’s proposal. Noted. See comment 171. 174. FEE 4.131 We that option 2 (only qualitative narrative for RC with figures included) best reflects objectives described in section 3 of the Impact Assessment. Narrative reporting should contain: - the nature of the risk concentration (single counterparty, sector, underlying risks, country …); - the measure used to quantify such exposure : assets, liabilities, sheet commitments, capital at risk, number of claims… - the rationale used to determine what is considered by undertakings to be an “important exposure”. Noted. See comment 171. See also comments template on RC 176. Groupe Consultatif 4.131 We agree that qualitiative reporting with figures would better meet the objectives. The data required in the current template is not clear (see comments on template). The figures required could be information such as that included in the helper tab for QIS5 for market concentration risk combined with references to the reinsurance templates. Noted. See comment 171. See also comments template on RC 177. IUA (INTERNATIONAL UNDERWRITING ASSOCIATION) 4.131 Risk concentration We agree that the option for only qualitative narrative for risk concentration would be more meaningful and effective. Noted. See comment 171. See also comments template on RC 178. RSA Insurance Group plc 4.131 We agree with EIOPA: the current proposed form duplicates, in part, reporting for assets (D series) and reinsurance (e.g. J3). There is no new information being reported here in these areas, so these elements should be withdrawn at the very least. Further, the proposed requirements for the SFCR and RSR already include disclosures on risk concentrations, for each of the major types of risk. Such Noted. See comment 171. See also comments template on RC
Comments_template_Impact_Assessment_final.docx