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comments: | Please indicate if your comments should be treated as confidential: | ~~Confidential/~~ Public |\n| Please follow the following instructions for filling in the template:\u003Cbr>􀃖 Do not change the numbering in the column “reference”; if you change numbering, your comment cannot be processed by our IT tool\u003Cbr>􀃖 Leave the last column empty.\u003Cbr>􀃖 Please fill in your comment in the relevant row. If you have no comment on a paragraph or a cell, keep the row empty.\u003Cbr>􀃖 Our IT tool does not allow processing of comments which do not refer to the specific numbers below.\u003Cbr>o Certain rows represent a group of cells with similar information (ex : TPE3-cells A17-A31-J16 for a given triangle in TP-E3)\u003Cbr>o Cells that refer to formulas are not mentioned in specific rows; in case you have comments on formulas, please make them in the cell“general” for the given template\u003Cbr>o In spreadsheets & LOGs, certain cell number may seem like they are missing (ex : going directly from cell B1 to cell B3); this is normal, as they may refer to a previously existing cell that has been deleted during informal consultations, and cell numberings have not been changed for integral consistency purposes\u003Cbr>o If your comment refers to multiple cells or paragraphs, please insert your comment at the first relevant paragraph and mention in your comment to which other cells or paragraphs this also applies.\u003Cbr>o If your comment refers to subparagraphs or specific cells within a group, please indicate this in the comment itself.\u003Cbr>Please send the completed template,  in Word Format, tocp009@eiopa.europa.eu. Our IT tool does not allow processing of any other |  |  |\n\n\n| Comments Template on\u003Cbr>Draft proposal for Quantitative Reporting Templates\u003Cbr>Deadline\u003Cbr>20 January 2012\u003Cbr>12:00 CET |  |  |\n| --- | --- | --- |\n| formats.\u003Cbr>The numbering of the paragraphs refers to this Consultation Paper, the numbering of cells refers to the accompanying spreadsheets and LOGs, the reference to “General”,“Purpose”, etc. refers to summary documents. |  |  |\n| Reference | Comment |  |\n| General Comment | The CEA would like to thank EIOPA for engaging in discussions with the industry to ensure the contents of the quantitative reporting templates (QRTs) package will be considered well in advance of entry into force of Solvency II. The industry expects that 18 months is required to implement the necessary systems and procedures to support systematic reporting of Solvency II information.\u003Cbr>The European (Re)Insurance industry does however have some outstanding concerns which we would ask EIOPA to consider before finalising the QRTs package.\u003Cbr>This level of reporting will be a requirement for the first time: it is therefore important that EIOPA consult further on the application of proportionality and materiality. The CEA has not commented specifically on the impact assessment however related comments can be found in response to this consultation.\u003Cbr>Not all templates have been simplified for public disclosure purposes: the statutory accounting column of the Solvency II balance sheet should be removed and replaced with a qualitative explanation of the differences arising direct comparisons of Solvency II and accounting valuation bases. The Own Funds template also requires further simplification.\u003Cbr>Quarterly reporting should be applied in a proportionate way: infra-annual reporting could be limited to situations when there is a material change to calculations underlying the SCR and technical provisions. Simplifications and approximations would also help to facilitate more frequent systematic reporting.\u003Cbr>EIOPA should drop the requirement to report Q4 templates: year-end reporting will follow within the same quarter providing a more detailed breakdown of validated |  |\n\n\n| Comments Tem","cbCaissdlWLjP0su","https://ap.wps.com/l/cbCaissdlWLjP0su","pdf",1671687,274,"English","# Comments template instructions\n## Confidentiality and submission rules\n## General comments on QRTs package","[{\"question\":\"Who is the comments template addressed to and what is its purpose?\",\"answer\":\"The template addresses EIOPA and is used to submit company comments on the draft Quantitative Reporting Templates (QRTs) package under Solvency II.\"},{\"question\":\"What key rules must be followed when filling in the template?\",\"answer\":\"The document instructs users not to change numbering in the reference column, leave the last column empty, and enter comments only in the relevant rows that match the specific numbers the IT tool can process.\"},{\"question\":\"What are CEA’s main concerns reflected in the general comments?\",\"answer\":\"CEA highlights concerns about implementation timing, the need for further consultation on proportionality and materiality, insufficient simplification for public disclosure, and burdensome requirements such as reporting Q4 templates and asset data.\"}]","Comments Template on Draft proposal for Quantitative Reporting Templates - 20 January 2012 - 12:00 CET | PDF",96]