158. Royal London Cover A1A- This comment applies to all the expenses cells L1 to P1. The Log Please see Com. 155 – – Group cell L1A refers to expenses This implies that these shouldbe on a cash ‘paid’. basis. This should be changed to an accruals basis as this is the way that expenses are recorded and used by management. This comment applies to all expenses cells L1 to P1. The template asks for expenses gross and net of reinsurance. The Log definition is ceded to reinsurance’. Expenses are not ceded to reinsurers. ‘share The reinsurers’ share of expenses lines should be deleted. The definition of admin expenses is not clear. For example it is not clear what would be included here and not in overheads and It would be much simpler if there was a single category of expenses, as on A1Q. Alternatively there should be fewer categories of expenses, for example : Acquisition costs, investment management costs, costs of servicing business (including claims) and other. 159. Association of Cover A1A- See comment in L1A above. Reinsurers’ share of expenses is Please see Com. 155 – British Insurers cell M1A meaningless and should be deleted. (ABI) 160. Deloitte Touche Cover A1A- The split in expenses paid may be challenging to provide for smaller Please see Com. 108 – Tohmatsu cell M1A 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. 161. Royal London Cover A1A- See comment in L1A Reinsurers’ share of expenses is Please see Com. 155 – Group cell M1A meaningless and should be deleted. 162. Deloitte Touche A1A- The split in expenses paid may be challenging to provide for smaller Noted – Tohmatsu cell O1 undertakings.
158. Royal London Group Cover – A1A- cell L1A This comment applies to all the expenses cells – L1 to P1. The Log refers to expenses ‘paid’. This implies that these shouldbe on a cash basis. This should be changed to an accruals basis as this is the way that expenses are recorded and used by management. This comment applies to all expenses cells L1 to P1. The template asks for expenses gross and net of reinsurance. The Log definition is ‘share ceded to reinsurance’. Expenses are not ceded to reinsurers. The reinsurers’ share of expenses lines should be deleted. The definition of admin expenses is not clear. For example it is not clear what would be included here and not in overheads and It would be much simpler if there was a single category of expenses, as on A1Q. Alternatively there should be fewer categories of expenses, for example : Acquisition costs, investment management costs, costs of servicing business (including claims) and other. Please see Com. 155 159. Association of British Insurers (ABI) Cover – A1A- cell M1A See comment in L1A above. Reinsurers’ share of expenses is meaningless and should be deleted. Please see Com. 155 160. Deloitte Touche Tohmatsu Cover – A1A- cell M1A 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. 108 161. Royal London Group Cover – A1A- cell M1A See comment in L1A Reinsurers’ share of expenses is meaningless and should be deleted. Please see Com. 155 162. Deloitte Touche Tohmatsu – A1A- cell O1 The split in expenses paid may be challenging to provide for smaller undertakings. Noted
Comments_template_QRT_Cover_final.docx