additional costs disproportionate to the impact. If supervisors need the reconciliation reserve difference to be explained they could require additional items in the Reconciliation Reserve section of OF-B1Q to explain it, or notes attached to the return. This appears to be covered in the SFCR (Guideline 22(f)) 121. RSA Insurance 4.92 Given forms E1Q and F1Q are not applicable to groups, it would appear that Noted.See comment 111 plc the proposed exemption is not available to groups. If that is the intention, we believe that is disproportionate and we should like to understand the reasons for this unless the financial stability templates proposals have already been – anticipated. Further, it appear once the assets, technical provisions and own funds – have been reported there would be little benefit to this exemption, since – nearly all the work required to produce a balance sheet will have been done anyway. It is also unclear if the quarterly QRTs will actually help explain the quarterly reconciliation reserve movement required under paragraph 4.90. Finally, the conditions are met only when reconciliation reserve is explained by these other templates there is an implicit materiality “sufficiently” – threshold to be applied, i.e. needs to be clearly defined. “sufficiently” The proposed exemption would therefore appear to yield any benefit only in a very limited number of circumstances. 122. The Directorate 4.92 The ECB/Eurosystem currently collects timely and high quality monthly or See comment 111 General Statistics quarterly statistics for large parts of the euro area financial sector but avails (DG-S) of the E only of very limited statistical information on the insurance corporations (IC) sector. Accordingly, improved and detailed quarterly balance sheet information, both on a solo/non-consolidated basis and on a group/consolidated basis has been highlighted by users as an essential requirement. Therefore, template BS-C1 is key for ECB purposes, for information that cannot be derived from quarterly reporting of detailed
additional costs disproportionate to the impact. If supervisors need the reconciliation reserve difference to be explained they could require additional items in the Reconciliation Reserve section of OF-B1Q to explain it, or notes attached to the return. This appears to be covered in the SFCR (Guideline 22(f)) 121. RSA Insurance plc 4.92 Given forms E1Q and F1Q are not applicable to groups, it would appear that the proposed exemption is not available to groups. If that is the intention, we believe that is disproportionate and we should like to understand the reasons for this – unless the financial stability templates proposals have already been anticipated. Further, it appear – once the assets, technical provisions and own funds have been reported – there would be little benefit to this exemption, since nearly all the work required to produce a balance sheet will have been done anyway. It is also unclear if the quarterly QRTs will actually help explain the quarterly reconciliation reserve movement required under paragraph 4.90. Finally, the conditions are met only when reconciliation reserve is explained “sufficiently” by these other templates – there is an implicit materiality threshold to be applied, i.e. “sufficiently” needs to be clearly defined. The proposed exemption would therefore appear to yield any benefit only in a very limited number of circumstances. Noted.See comment 111 122. The Directorate General Statistics (DG-S) of the E 4.92 The ECB/Eurosystem currently collects timely and high quality monthly or quarterly statistics for large parts of the euro area financial sector but avails only of very limited statistical information on the insurance corporations (IC) sector. Accordingly, improved and detailed quarterly balance sheet information, both on a solo/non-consolidated basis and on a group/consolidated basis has been highlighted by users as an essential requirement. Therefore, template BS-C1 is key for ECB purposes, for information that cannot be derived from quarterly reporting of detailed See comment 111
Comments_template_Impact_Assessment_final.docx