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					FINAL                                                                                          Preliminary considerations                       1


According to § 1-4 of the Helsinki Protocol, this "Protocol must be seen as an enabling protocol. The competent supervisory authorities
take upon themselves to put in all reasonable efforts to co-operate in order to exercise the supplementary supervision.” The Helsinki
Protocol contains only very general principles that were developed in more precise recommendations in the "Guidelines on CoCos" and
the "Guidelines on Information Exchange between Lead Supervisors and other competent authorities". The Review Panel,
therefore, assesses the compliance with these 2 Guidelines.
Following the ECOFIN Roadmap of 4 December 2007 as well as the Council Conclusions on the EU supervisory framework and financial
stability arrangements of 14 May 2008, CEBS and CEIOPS drafted 10 Common Principles for Colleges of Supervisors (CEIOPS-SEC-
54/08/CEBS 2008 124) that were sent to the political level in June 2008 and published on the CEIOPS website end of January 2009.



The 10 Common Principles (the Principles) are an addition to the guidelines under the Helsinki protocol. CEIOPS anticipates revising
the guidelines in 2009 in order to incorporate these additions from the Principles. These additions, however, will not result in major
changes in the guidelines;only some requirements will change from “may” to “shall”. The Review panel will assess both the
implementation of the Helsinki guidelines as well as the Principles. Given the recent date of publication of the 10 Common Principles not all
CoCos have yet finalised the implementation of the 10 Principles. CEIOPS' Members Meeting of March 2009 decided that benchmarking of
the compliance will be done on the basis of the 10 Common Principles, given the current focus on the organisation of supervisory colleges

Regarding the Principles the wording “Colleges of Supervisors” refers for the purpose of this review to “Coordination Committees”.

Parallel to this process, the Principles as well as the Helsinki guidelines form the basis of the CEIOPS advice for the Level 2 implementing
measures on Colleges of Supervisors under Solvency II. This advice will be published for consultation in July this year.


In view of the proportionality principle please make clear in your comments the context in which your answer is provided.

Answers should be provided for insurance groups listed on the Helsinki List.



MS: Member State
MSCA: Member State Competent Authority
CA: Competent Authority
LS: Lead Supervisor
CoCos: Coordination Committees




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FINAL                                      Preliminary considerations   2




61e6d672-a310-44a9-b349-1e57dee3fa0f.xls
FINAL                                                                                                                                Guidelines for replying



Each question should be answered by Y, N, NA or NC:
   Y: if the requirement is in general complied with for actual cases (to be explained in COMMENTS)
   N: if the requirement is in general not complied with for the majority of actual cases (to be explained in COMMENTS)
   NA (NOT APPLICABLE): if the requirement is not relevant for the authority and therefore a case could not occur (to be explained in COMMENTS)
   NC (NO CASES): if there are no actual cases yet or no experience with the respective requirement (to be explained in COMMENTS)


If existing, the national IMPLEMENTING MEASURES* related to the specific protocol requirement should be given:
   - the reference (title, date, ...) and relevant articles of the law, secondary regulation, circulars, ...
   - a link to the website or a copy of the implementing measures should be provided (Please provide these copies as an attachment to your reply
   and indicate clearly to which question they belong)

Each answer should be commented (COMMENTS**), taking following general guidelines into consideration:
   if Y:    Are requirements always complied with? If not, why and what is the % and the number of cases which were not complied with.
   if N:    Why is this requirement not complied with ? Please identify the reasons why and the possible remedies.
   if NA:   Why is this requirement not relevant for your authority ? Please explain why a case could never occur in your jurisdiction.
   if NC:   Why are there no actual cases up till now ? What are your expectations with regard to the emergence of actual cases (how
            many and in what timeframe) ?
   for all: How does your organisational structure (procedures, dedicated team, ...) ensure the compliance of the requirement, whether
            or not an actual case has already occurred ?
   for      In the column 'GUIDANCE FOR COMMENTS' you will find requests for specific comments. Please provide your answer to these
   some: questions in the column 'COMMENTS'. If specific data is requested such as number of cases, an average timing etc.. please provide the
            figures in the columns 'DATA'.

 * See articles 22 to 27 of the Methodology for Peer Review:
   22.If a supervisory provision or practice has been applied, either in full or partially, the CEIOPS Member must provide information on the national
   implementing measures, including policies, procedures and other practices implemented, considering that peer review aims at compliance and
   convergence in practice, not just from a legal perspective.
   23.National implementing measures may include laws (i.e. acts of Parliament) and regulations (i.e. decrees of ministries or rule books of CEIOPS
   Members), guidelines and circulars of CEIOPS Members (provided that non-compliance with these guidelines and circulars should trigger
   enforcement action by the CEIOPS Member concerned), rules of self-regulatory organisations, such as industry associations (where applied by a
   significant part of the industry in a specific Member State and provided that non-compliance with those rules triggers enforcement action by the
   self-regulatory organisation concerned or by the CEIOPS Member), and relevant case law. Internal procedures followed by CEIOPS Members that
   do not trigger enforcement action are also classified as implementing measures for these purposes.

   24.If a national implementing measure is considered by the relevant CEIOPS Member as going beyond the „requirements‟ of the supervisory
   provision or practice subject to peer review, this fact should be stated.
   25.Any derogation from a national implementing measure or any possibility for issuing a waiver from the „requirement‟ should be stated explicitly,
   together with the rationale for any such exemption, and should be taken into account in the self-assessment.
   26.If a national implementing measure is not in force but has already been formally adopted, and there is a concrete date of its coming into force
   within a reasonable period of time after the peer review exercise has started, it must be assessed as if it had been in force at the time of the self-
   assessment. The Review Panel will establish what is a „reasonable period of time‟.
   27.If a national implementing measure relating to the supervisory provision or practice subject to peer review is in the process of being drawn up,
   this fact has to be stated, provided that the implementing measure is already in a concrete stage (e.g. a proposal to Parliament or publication of a
   consultation paper).


** See articles 21 and 28 of the Methodology for Peer Review:
   21.If a supervisory provision or practice is not applicable, the CEIOPS Member must state the reason for its nonapplicability. In such cases, the
   supervisory provision or practice will be classified as „not applicable ‟.
   28.If a supervisory provision or practice has not been fully applied, the CEIOPS Member must state, at a minimum, the reason for the non-full
   application, and, if applicable, the action taken so far to achieve full application, and the proposed timing of full application.




61e6d672-a310-44a9-b349-1e57dee3fa0f.xls
FINAL                                                                                                                           Questionnaire HP - Info Xchange                                                                                                                      4



Helsinki Protocol
Guidelines on Information Exchange between lead supervisors and other competent authorities
              Articles                                                  Assessment criteria                                No Questions                                           Guidance for comments                Answers (See guidelines for replying)                         Benchmarks
              and relevant paragraphs                                                                                                                                                                                  Your reply    Implementing Comments           Fully applied
                                                                                                                                                                                                                                     measures
1.           3. A communication strategy should be developed under the           Regarding the development of a            1   Have you already initiated the development of a Please describe how you define                                     FME is not a     if a positive
Communicat auspices of the lead supervisor, in full consultation with other      communication strategy.                       communication strategy for each of the key      "key" groups and please                                            lead supervisor answer to 1 and
ion strategy competent authorities. The strategy should coordinate at a minimum                                                groups of which your authority is lead          provide us with a list of key                                      of any insurance 2
             the gathering and the dissemination of information. It should have                                                supervisor?                                     groups in your jurisdiction (See                                   group nor
             regard to defining by whom and to whom information should be                                                                                                      Annex 1). This list will be                                        member of
             disseminated, be it between other competent authorities and the                                                                                                   treated as confidential and will                                   CoCo.
             lead supervisor or bi- or multi-laterally between other competent                                                                                                 hence not be made public).                   NC
             authorities. In particular, supervisors should ensure insofar as
             possible under relevant national legislation that:                                                                                                                   If you are not a lead supervisor
             • the lead supervisor has unfettered access to all relevant                                                                                                          for any cross-border group
             information;                                                                                                                                                         please answer "NA: not
             • essential information and, if deemed useful, relevant information                                                                                                  applicable".
             is provided to all supervisors at an appropriate level and
             • no undue limitations are imposed on spontaneous communication                                               2   Have you initiated the development of a            Are you prepared to develop in                                  FME is not a
             between supervisors.                                                                                              communication strategy for each of the other       the future communication                                        lead supervisor
                                                                                                                               groups?                                            strategies for all the other                                    of any insurance
              The process may naturally lead to an asymmetric flow of                                                                                                             groups?                                   NC                    group nor
              information.                                                                                                                                                        Please describe your                                            member of
                                                                                                                                                                                  preparedness.                                                   CoCo.
              Principle 7: The Colleges of Supervisors provide an efficient
                                                                                      The Colleges of Supervisors shall    3   As a Lead Supervisor have you set a template                                                                       FME is not a     if a positive
              platform for the gathering and dessimination of relevant or
                                                                                      ensure, subject to confidentiality       or any other standard format to gather                                                                             lead supervisor answer to 3 or 4
              essential information in going concern and emergercy situations,                                                                                                                                              NC
                                                                                      provisions, all relevant                 information from host supervisors?                                                                                 of any insurance
              developing a common understanding of the risk profile of the Group,
                                                                                      information needed for the                                                                                                                                  group nor
              achieving coordination of supervisory review and risk assessment at
                                                                                      supervision of the Group is          4   As a Lead Supervisor have you chosen a case                                                                        FME is not a
              Group level as well as establishing supervisory plans for the
                                                                                      collected and disseminated in a          by case approach where the information asked                                                                       lead supervisor
              mitigation of risks at Group level.
                                                                                      timely manner to the relevant            for, depends on the group?                                                                                         of any insurance
                                                                                      supervisory authorities, (...)                                                                                                                              group nor
                                                                                                                                                                                                                            NC
                                                                                                                                                                                                                                                  member of
                                                                                                                                                                                                                                                  CoCo.



2. Relevant 6. „Relevant information,‟ is understood to mean information that is      It is not up to the lead supervisor 5    As a Host Supervisor,
information relevant to the performance of another supervisor‟s obligations.          to consider which information is         a) Do you consider that the information                                                                            FME is not a
            Supervisors in each Coordination Committee should agree on the            relevant or not; According § 4 & 6       disseminated by the Lead Supervisor is                                                                             lead supervisor
            scope of relevant information to be communicated, and may                 "relevant information" is the            sufficient for performing efficiently your                                                                         of any insurance
                                                                                                                                                                                                                            NC
            consider specifying the content, format, and the manner in which          information which is deemed to           supervision on the subsidiaries incorporated in                                                                    group nor
            information will be exchanged (e.g. contacts, regular conference          be necessary by the host                 your jurisdictions?                                                                                                member of
            calls, regular meetings, written agreements etc). Supervisors             supervisor.                                                                                                                                                 CoCo. not a
            requesting information should state clearly the purpose for which                                                  b) In the positive to question 5 a), do you as                                                                     FME is
            the information is requested. This will help to assess relevance.                                                  host MSCA nevertheless request relevant                                                      NA                    lead supervisor
                                                                                                                               information for specific needs?                                                                                    of any insurance
              7. The lead supervisor shall provide other competent authorities                                                                                                                                                                    group nor
                                                                                                                               c) In the negative to question 5 a), do you as                                                                     FME is not a
              with all relevant information. In determining the extent of relevant                                             host supervisor, inform the lead supervisors                                                                       lead supervisor
              information, the importance of the subsidiaries within the financial                                             about what you consider as relevant                                                          NA                    of any insurance
              system of the Member                                                                                             information?                                                                                                       group nor
              States where they are authorized should be taken into account. If                                                                                                                                                                   member of
                                                                                                                           6   As a Host Supervisor,
              structural changes in a group entail the involvement of new or the
              exclusion of existing supervisors, the lead supervisor will monitor a                                            a) In the positive of 5 b) or 5 c) do you consider As host supervisor do you                                       FME is not a     if yes to 6 c
              proper handover and an effective continuation of the cooperative                                                 the same information as relevant for all the       motivate your requests to the             NA                    lead supervisor
              process.                                                                                                         groups?                                            lead supervisor according the                                   of any insurance
                                                                                                                                                                                  specific situation of the insurer:                              group nor
                                                                                                                               b) In the positive of 5 b) or 5 c) did you chose a                                                                 FME is not a
                                                                                                                                                                                   □ place on the market,
                                                                                                                               case by case approach where the information                                                                        lead supervisor
                                                                                                                                                                                   □ financial position of the              NA
                                                                                                                               asked for, depends of the group?                                                                                   of any insurance
                                                                                                                                                                                  group,
                                                                                                                                                                                                                                                  group nor
                                                                                                                                                                                   □ risk exposure,
                                                                                                                               c) In the positive of 6 a) or 6 b), do you state                                                                   member of a
                                                                                                                                                                                                                                                  FME is not
                                                                                                                                                                                   □ other information
                                                                                                                               clearly the purpose of the individual request of   ………………………….)                                                    lead supervisor
                                                                                                                               information?                                                                                 NA                    of any insurance
                                                                                                                                                                                                                                                  group nor
                                                                                                                           7   As a lead supervisor, do you provide the                                                                           member of a
                                                                                                                                                                                                                                                  FME is not       if yes to 7
                                                                                                                               information the host MSCA considers relevant?                                                NC                    lead supervisor
                                                                                                                                                                                                                                                  of any insurance
                                                                                                                                                                                                                                                  group nor
                                                                                                                           8   Did the Co-Co agree on the scope of relevant                                                                       FME is not a
                                                                                                                               information to be communicated?                                                              NC                    lead supervisor
                                                                                                                                                                                                                                                  of any insurance
                                                                                                                                                                                                                                                  group nor




61e6d672-a310-44a9-b349-1e57dee3fa0f.xls
FINAL                                       Questionnaire HP - Info Xchange   5




No     Benchmarks
     Partially applied      Not applied


1    if a positive answer   if a negative
     to 1 and a negative    answer to 1
     answer to 2




2




3                           if a negative
                            answer to 3
                            and 4

4




5




6
                            if no to 6 c




7                           if no to 7



8




61e6d672-a310-44a9-b349-1e57dee3fa0f.xls
FINAL                                                                                                                                                                     Questionnaire HP - Cocos                                                                                                                        6




Helsinki Protocol
Guidelines for Coordination Committees in the Context of Supplementary Supervision as Defined by the Insurance Groups Directive (98/78/EC).
              Articles                                                                  Assessment criteria                No   Questions                                           Guidance for comments               Answers (See guidelines for replying)                             Benchmarks
              and relevant paragraphs                                                                                                                                                                                   Your reply     Implementing Comments        Fully applied        Partially applied Not applied
                                                                                                                                                                                                                                       measures
2.1.          Guideline article 2.1:                                              Each supervisor has to ensure            1    Did you for each undertaking in your jurisdiction                                                                   FME is not a    if yes                                if no
Members of    There is one CoCo for each and every insurance group operating in   that for each undertaking in its              belonging to a group operating in more than one                                                                     member of
the CoCo      more than one EEA-country.                                          jurisdiction belonging to a group             EEA -country identify a CoCo?                                                                                       CoCo. No
                                                                                  that is operating in more than                                                                                                                                    internation
              The CoCo members are representatives of the Insurance               one country a CoCo exists (of                                                                                                               NC                    groups under
              Supervisory Authorities in the Member States in which the Group     course one expects the                                                                                                                                            FME supervision
              has undertakings, and would normally be responsible for the day-to- proportionality principle to be
              day supervision of the Group in their state.                        applied).
                                                                                        Each supervisor should be          2    Do you ensure that you are represented in all       Is the representative                                             The FME is not   if yes                             if no
                                                                                        represented in a CoCo for an            CoCos you should be?                                responsible for the day-to-day                                    a lead
                                                                                        undertaking in its jurisdiction                                                             supervision of the undertaking                                    supervisor of
                                                                                        belonging to a group that is                                                                part of the group?                        NC                      any insurance
                                                                                        operating in more than one                                                                                                                                    group.
                                                                                        Member State.
                                                                                        Each CoCo lead supervisors         3    For all Groups for which you are the lead                                                                             The FME is not   if yes                             if no
                                                                                        should invite the supervisors of        supervisor, did you invite representatives of                                                                         a lead
                                                                                        all member states in which the          the supervisory authorities from every member                                                 NC                      supervisor of
                                                                                        Group has undertakings.                 state in which the group has undertakings to be                                                                       any insurance
                                                                                                                                part of the CoCo?                                                                                                     group.
              Principle 1:                                                              If deemed necessary, supervisors 4      As lead supervisor, did you assess the              Please describe your                                              The FME is not   if yes                             if no
              The supervisors of the Member States involved in the                      of                                      relevancy of inviting supervisors of branches ?     assessment criteria.                                              a lead
              supervision of any of the relevant activities of a cross-border           systemically relevant branches                                                                                                                                supervisor of
              insurance group, banking group or a financial conglomerate,               should be invited to the College.                                                                                                                             any insurance
              hereinafter called a “Group” shall form a “College” (College of           The host supervisors of significant                                                                                                   NC                      group.
              supervisors).                                                             branches may be invited to join
                                                                                        the College.


2.2.          Guideline article 2.2:                                                    Where groups are part of a        5     For those cross-border insurance groups where       Please describe how (e.g. info                                    The FME is not   if yes                             if no
Supplement    The IGD states that with regard to financial conglomerates, the           financial conglomerate the lead         you are the lead supervisor and that are part       exchange, invitation to the                                       a lead
ary           CoCo will cooperate with authorities responsible for the supervision      supervisor has to ensure that the       of a financial conglomerate, do you involve the     CoCo meeting, supervisory                                         supervisor of
supervision   of other financial sectors, in order to ensure more efficient solo-plus   coco cooperates with the                other supervisors responsible for the supervision   work plan, joint inspections, ..)                                 any insurance
              supervision.                                                              authorities responsible for the         of the other sectors in the work of the CoCos?                                                                        group.
                                                                                        supervision of the other sectors.
              Principle 2:                                                                                                                                                                                                    NC
              The College of supervisors shall provide an effective and flexible
              permanent forum for cooperation and coordination among the
              authorities responsible for and involved in the supervision of the
              Group. Where appropriate, Colleges may cooperate with other
              authorities.

              Guideline article 2.2.                                                    The organization of a CoCo should 6     Are the CoCos in which you participate              What channels are used for the                                    The FME is not
              Rather than face-to-face meetings, it may prove sufficient to             be proportionate to the                 proportionate to the organization, nature, scale    exchange of information?                                          a lead
              exchange information by other channels, including the use of the          organization, nature, scale and         and complexity of the insurance group and do        Please tick:                                                      supervisor of
              telephone conference, video conference, email and letter. The CoCo        complexity of the insurance group       they reflect the activities, risks and legal         □ telco                                                          any insurance
              may find it advantageous to arrange face-to-face meetings for more        and to the assessment of the            structure of the group?                              □ videoconference                                                group.
              complex groups, for an initial meeting, or for extraordinary              groups´ soundness. The CoCo                                                                  □ mail
              circumstance (e.g., crisis)                                               should reflect the activities, risks                                                         □ letter
                                                                                        and the legal structure of the                                                               □ face-to-face meetings                  NC
              Principle 3:                                                              insurance group.
              The organization of the Colleges of Supervisors is proportionate to                                                                                                   In which circumstances are
              the organization, nature, scale and complexity of the Group and to                                                                                                    these used ?
              the assessment of the Group‟s soundness, and reflects the activities,
              risks and the legal structure of the Group.


              Principle 9:                                                              Common on-site inspections and 7        Regarding supervisory on-site inspections :
              The Colleges of supervisors shall have on their regular agenda,           joint examinations are important.
                                                                                                                                a) Are these regularly planned and coordinated                                                                        FME is not a     if yes to a, b,                    if no to a, b
              planning and coordination of supervisory on-site inspections,
                                                                                                                                within the CoCo ?                                                                             NC                      member of        or c                               and c
              including joint supervisory examinations, and the findings of such
                                                                                                                                                                                                                                                      CoCo. No
              visits will be shared by the Group Supervisor/Consolidated
                                                                                                                                b) Do these include joint inspections ?             In how many joint inspections                                     international
                                                                                                                                                                                                                                                      FME is not a
              Supervisor/Coordinator with the other supervisors in the College of
                                                                                                                                                                                    did you participate and in what                                   member of
              supervisors according to their respective needs and subject to                                                                                                                                                  NC
                                                                                                                                                                                    capacity (lead/host) ?                                            CoCo. No
              confidentiality provisions.
                                                                                                                                                                                                                                                      international
                                                                                                                                c) Are findings of such visits shared with other                                                                      FME is under
                                                                                                                                                                                                                                                      groups not a
                                                                                                                                supervisors in the CoCo, if needed?                                                           NC                      member of
                                                                                                                                                                                                                                                      CoCo. No
                                                                                                                                                                                                                                                      international




61e6d672-a310-44a9-b349-1e57dee3fa0f.xls
FINAL                                                                                                                                                                     Questionnaire HP - Cocos                                                                                                                            7




Helsinki Protocol
Guidelines for Coordination Committees in the Context of Supplementary Supervision as Defined by the Insurance Groups Directive (98/78/EC).
              Articles                                                                 Assessment criteria                   No   Questions                                          Guidance for comments              Answers (See guidelines for replying)                              Benchmarks
              and relevant paragraphs                                                                                                                                                                                   Your reply     Implementing Comments           Fully applied     Partially applied Not applied
                                                                                                                                                                                                                                       measures
2.1. Key
2.3.          Guideline article 2.1:
                                 2.3:                                                  A CoCo should appoint a Lead          8    Did the CoCos in which you participate appoint a                                                                    FME is not a
Members of
coordinator   There isbe useful for the CoCo to agree on one or moreoperating in
              It may one CoCo for each and every insurance group supervisors           Supervisor that coordinates the            Lead Supervisor?                                                                            NC                      member of
the CoCo
and lead      more than one EEA-country. whose role will be to coordinate the
              acting as Key Coordinator(s),                                            activities of the CoCo and                                                                                                                                     CoCo. No
supervisors   activities necessary to carry out the supplementary supervision.         organizes and chairs the CoCo         9    As a lead supervisor did you                                                                                        international    if yes to a and                      if no to a or b
                         may decide that a Lead Supervisor Insurance
              The CoCo members are representatives of theshall have a key role in      meeting.                                                                                                                                                                        b
              Supervisory Authorities in the Memberanalyzing it, and the Group
              pulling together relevant information, States in which                                                              a) initiate the cooperation process ?                                                                               The FME is not
              disseminating his and would normally the other members of the
              has undertakings, or her conclusions tobe responsible for the day-to-                                                                                                                                           NC                      a lead
              day supervision of the Group in their state.
              CoCo.                                                                                                                                                                                                                                   supervisor of
                                                                                                                                                                                                                                                      any insurance
                                                                                                                                  b) chair the meeting of the CoCo ?                                                                                  The FME is not
             Principle 6:                                                                                                                                                                                                                             a lead
             The Group Supervisor (for an Insurance Group) or Consolidating                                                                                                                                                                           supervisor of
             Supervisor (for a Banking Group) or the Coordinator (for a Financial                                                                                                                                                                     any insurance
                                                                                                                                                                                                                              NC
             Conglomerate), shall initiate the cooperation process, chair the                                                                                                                                                                         group.
             meeting of the College of supervisors, and be responsible for
             designing a work programme for the supervision of the Group, which
             shall be approved by the College of Supervisors.
3.           Guideline article 3:                                                      The lead supervisor is responsible 10      Q1: For all CoCos where you are the lead                                                                            The FME is not   if yes to 10.1    if yes to 10.1 and if no to 10.1
Preparation Prior to the meeting, the Lead Supervisor/Key Coordinator should           for (1) sending out a statement of         supervisor, do you send a statement of the                                                                          a lead           and 10.2          no to 10.2
for meetings set out a clear statement of the expected outcomes of the meeting         expected outcomes before the               expected outcomes of a CoCo meeting to the                                                  NC                      supervisor of
             and send this for comment to all participants.                            meeting and (2) sending this out           CoCo members?                                                                                                       any insurance
                                                                                       for comments before finalizing                                                                                                                                 group.
                                                                                                                                  Q2: For all CoCos where you are the lead           Did you receive many                                             The FME is not
                                                                                       the statement of expected
                                                                                                                                  supervisor do you request comments from all        comments on the statements                                       a lead
                                                                                       outcomes.                                                                                                                              NC
                                                                                                                                  CoCo members on the statement of expected          you sent out and how often do                                    supervisor of
                                                                                                                                  outcomes before finalizing it?                     you comment on statements                                        any insurance
              Guideline article 3:                                                     (1) the agenda for CoCos should 11         Q1: For all CoCos where you are the lead           received?
                                                                                                                                                                                     How many weeks/working days                                      group.
                                                                                                                                                                                                                                                      The FME is not   if yes to 11.1    if yes to 11.1 and if no to 11.1
              An agenda of the meeting, sent out 2-3 weeks in advance, should          be send out at least 2 weeks               supervisor, do you send out an agenda at least in advance do you usually send               NC                      a lead           and 11.2.a, b,    11.2.a             or 11.2.a
              clearly state which issues are going to be discussed, why these          before the meeting and (2) the             two weeks in advance of the meeting            the agenda?                                                          supervisor of    c
              items are being discussed and what will be expected from the other       agenda should clearly state which          Q2: Do the agendas clearly state:                  Please comment on nature of                                      any insurance
              members during the discussion (e.g. roundtable).                         issues are going to be discussed,                                                             the agenda and other
                                                                                       why these items are being                  a) which issues are going to be discussed?                                                                          The FME is not
                                                                                                                                                                                     documents distributed.                   NA                      a lead
                                                                                       discussed and what will be
                                                                                       expected from the other members                                                                                                                                supervisor of
                                                                                       during the discussion (e.g.                b) why these items are being discussed?                                                                             any insurance
                                                                                                                                                                                                                                                      The FME is not
                                                                                       roundtable).                                                                                                                           NA                      a lead
                                                                                                                                                                                                                                                      supervisor of
                                                                                                                                  c) what will be expected from the other                                                                             The FME is not
                                                                                                                                  members during the discussion?                                                              NA                      a lead
                                                                                                                                                                                                                                                      supervisor of
              Guideline article 3:                                                     The minutes/a summary of a        12       For all CoCos where you are the lead supervisor, How many weeks/working days                                        The insurance
                                                                                                                                                                                                                                                      any FME is not   if yes                               if no
              Minutes/a summary of the last meeting should be agreed upon a            CoCo meeting should be sent and            do you send out draft minutes/a draft summary after the last meeting do you                                         a lead
              few weeks after the meeting, to ensure that all points raised have       agreed upon a few weeks after              of the last meeting for agreement by written     usually send out the minutes?              NC                      supervisor of
              been followed up and addressed.                                          the meeting by all CoCo                    procedure upon a few weeks after the last                                                                           any insurance
              Guideline article 3:                                                     members. CoCo meeting there 13
                                                                                       During each                                meeting?
                                                                                                                                  For all CoCos where you are the lead supervisor                                                                     group. is not
                                                                                                                                                                                                                                                      The FME          if yes                               if no
              [S]upervisors should always have a separate and closed session for       should be separate closed session          do you organise a separate and closed session                                                                       a lead
              internal discussions, without the insurance group being present.         for internal discussion.                   for internal discussions without the insurance                                              NC                      supervisor of
                                                                                                                                  group being present?                                                                                                any insurance
                                                                                                                                                                                                                                                      group.
              Guideline article 3:                                                     All CoCo members should be able 14         For all CoCos where you are the lead supervisor,                                                                    The FME is not   if yes                               if no
              The Key-Coordinator/Lead Supervisor should endeavour to ensure           to read and understand all reports         do you endeavour to ensure that reports or                                                                          a lead
              that reports or other information is submitted in, or translated to, a   and other information that is              other information is provided in a language                                                 NC                      supervisor of
              language understood by all members in the CoCo of that insurance         discussed within the CoCo.                 understood by all members in the CoCo?                                                                              any insurance
              group.                                                                                                                                                                                                                                  group.

4.1.          Guideline article 4.1:                                                   All CoCos should have a written       15   Is the basis for cooperation in both regular and                                                                    FME is not a    if yes                                if no
Agreements    The CoCo may wish to lay down any arrangements on                        multilateral agreement in place            crisis situations in the CoCos in which you                                                                         member of
within the    supplementary supervision in written multilateral agreements, which      that addresses both regular and            participate laid down in a written agreement?                                                                       CoCo. No
CoCo          should address both regular and emergency situations, including          emergency situations.                                                                                                                                          internaltional
              dealing with potential conflicts of interest.                                                                                                                                                                                           groups under
                                                                                                                                                                                                                              NC                      FME supervision
              Principle 5:
              The Colleges of supervisors shall have agreements in place, laying
              out the basis for the cooperation between the involved authorities
              and the practical organisation of the supervisory activities of the
              Group on a on-going basis and in a crisis situation, including
              engagement with Cross Border Stability Groups.
                                                                                       All CoCos should have a working       16   As a LS, did you design a a working plan for the                                                                    The FME is not   if yes                               if no
              Guideline article 4.1:                                                   plan for the supervision of the            CoCos in which you participate?                                                                                     a lead
              Of further use may be the agreement of a working plan, indicating        group. A woking plan could                                                                                                                                     supervisor of
              frequency and form of meetings, how to share information on a            indicate the frequency and form                                                                                                                                any insurance
              continuous basis, etc.                                                   of meetings, the way to shar                                                                                                                                   group.
                                                                                       einformation on a continuous
              Principle 6:                                                             basis, etc..                                                                                                                           NC
              The Group Supervisor (for an Insurance Group) or Consolidating
              Supervisor (for a Banking Group) or the Coordinator (for a Financial
              Conglomerate), shall initiate the cooperation process, chair the
              meeting of the College of Supervisors, and be responsible for
              designing a work programme for the supervision of the Group, which
              shall be approved by the College of Supervisors.
4.2. Crisis   Guideline article 4.2:                                                   (1) A CoCo should analyse             17   Q1: Did all CoCos in which you participate         (confidential): list the CoCos                                                    if yes to 17.1                       if no to 17.1
situations    [T]o be fully prepared for any action that may be required, the CoCo     beforehand any crisis situation            analyse beforehand any crisis situation that may that you think have fulfilled this                                                  and 17.2                             or 17.2
                                                                                                                                                                                                                              NC
              should analyse beforehand any crisis situation that may arise and        that may arise including any               arise including any potential confict of interest? requirement and those which
              any potential conflicts of interest. Furthermore, the CoCo should        potential conflict of interest and                                                            did not
              agree on a specific emergency plan, including cooperation and            (2) the CoCo should have an                Q2: Do all CoCos in which you participate have
              coordination in these kinds of situations.                               emergency plan ready in case               an emergency plan?                                                                          NC
                                                                                       there is a crisis within the group.




61e6d672-a310-44a9-b349-1e57dee3fa0f.xls
FINAL                                                                                                                                                                           Questionnaire HP - Cocos                                                                                                                      8


4.2. Crisis
situations
Helsinki Protocol
Guidelines for Coordination Committees in the Context of Supplementary Supervision as Defined by the Insurance Groups Directive (98/78/EC).
                Articles                                                                 Assessment criteria                   No   Questions                                             Guidance for comments              Answers (See guidelines for replying)                            Benchmarks
                and relevant paragraphs                                                                                                                                                                                      Your reply     Implementing Comments           Fully applied    Partially applied Not applied
                                                                                                                                                                                                                                            measures
2.1.            Guideline article 2.1:
                                    4.2:                                                 Supervisory authorities shall          18 Q1: Do you consult the supervisors in the CoCo         How do you determine                                                              if yes                            if no
Members of      There issituation may be identified for insurance group within an in
                A crisis one CoCo for each and every an undertaking operating            consult with each other prior to          prior to making any important decision that            "important"?
the CoCo        insurance one EEA-country.
                more thangroup by one Supervisory Authority. The supervisor              making any important decisions            might affect the group as a whole, or other            How do you assess the impact             NC
                responsible for the “solo” supervision of the insurance undertaking      that might affect the Group as a          entities within the group ?                            on the group or the other
                The CoCo members are representatives of the Insurance members
                shall take the appropriate measures and inform the other                 whole, or other entities within the                                                              entities ?
                of the CoCo Authorities basis, and if possible in which the Group
                Supervisory on a timely in the Member States beforehand of the           Group.                                     Q2: If you identify a crisis situation as                                                                                               if yes to Q2 a                    if no to Q2 a
                has undertakings, and would normally be responsible for the day-to-
                measures taken.                                                                                                     supervisory authority of an undertaking                                                                                                 and b                             or b
                day supervision of the Group in their state.                             However, in a crisis situation, the        belonging to an insurance group:
                Principle 8:                                                             supervisory responsible should
                The Colleges of supervisors promote harmonization of approaches          take appropriate measures and
                                                                                                                                    a) Do you inform the CoCo on a timely basis?                                                   NC
                and coordinates input to major supervisory decisions taken by            inform all CoCo members on a
                                                                                                                                    b) Do you inform the CoCo beforehand of the
                individual authorities as far as possible and practicable, and draw      timely basis, and if possible
                                                                                                                                    measures taken, if possible?
                their conclusions where appropriate.                                     beforehand of the measures
                                                                                         taken.                                                                                                                                    NC



                Guideline article 4.2:                                                   In crisis situations CoCos should 19       Did the CoCos in which you participate agree on Please elaborate on the specific                                                        if yes                            if no
                In a crisis situation some of the available information on the           have and use alternative forms of          alternative forms of communication for crisis   means used.
                insurance group could be commercially or market sensitive. The           information in order to safeguard          situations?                                                                                    NC
                CoCo should consider alternative forms of communication, avoiding        the confidentiality of information
                use of email transmission.                                               that is exchanged.

4.4. Internal   Guideline article 4.4:                                                   The Lead supervisor should        20       Q1: As Lead Supervisor, do you ensure that                                                                             The FME is not   if yes to 20.1                    if no to 20.1
Control         It is recommended that within the internal control and risk              ensure that the CcCo has a clear           the CoCos assess the control and risk                                                          NC                      a lead           and 20.2                          or 20.2
mechanisms      management framework, the CoCo should look at the specific group-        picture of the control and risk            management framework of the group?                                                                                     supervisor of
and risk        relevant risks in more detail, including for example the reinsurance     management framework at group                                                                                                                                     any insurance
                                                                                                                                    Q2: As Lead Supervisor, do you ensure that                                                                             The FME is not
managemen       program, distribution channels used in the different countries, the      level in order to be aware of the
                                                                                                                                    the CoCos assess specific group-relevant risks                                                                         a lead
t processes     investment policies applied or the extent to which internal audit        specific group-relevant risks.
                                                                                                                                    in more detail?                                                                                                        supervisor of
                follows and audit plan applicable at group level.
                                                                                                                                                                                                                                                           any insurance
                                                                                         Involved supervisors shall, where
                                                                                                                                                                                                                                                           group.
                Principle 7:                                                             appropriate, contribute their
                The Colleges of Supervisors provide an efficient platform for the        information and assessments of
                gathering and dissemination of relevant or essential information in      their supervised entities to the
                going concern and emergency situations, developing a common              overall assessment of risks and
                understanding of the risk profile of the Group, achieving                financial soundness of the Group                                                                                                          NC
                coordination of supervisory review and risk assessment at Group          by the Lead supervisor to be
                level as well as establishing supervisory plans for the mitigation of    addressed in the CoCo and will be
                risks at Group level.                                                    vice versa informed on the
                                                                                         results.
                Principle 10:
                Within the College of supervisors, the supervisors review and
                evaluate risks to which the group and its entities are or might be
                exposed to ensure a prospective supervision and foster early-
                Guideline article 4.4:                                                 Lead supervisors are responsible 21          As LS, do you ensure that the CoCos look at                                                                            The FME is not   if yes                            if no
                The CoCo should furthermore be looking at how the management           for the CoCo to ensure that the              how the management information systems                                                                                 a lead
                information systems contribute in giving the management and the        management and board of an                   contribute in giving the management and the                                                                            supervisor of
                                                                                                                                                                                                                                   NC
                board a reliable and global view of the real situation of the Group as insurance group have a good                  board a reliable and global view of the real                                                                           any insurance
                a whole.                                                               picture of the real situation of the         situation of the Group as a whole?                                                                                     group.
                                                                                       group.
                The CoCo should also be reassured that clear lines of responsibilities Lead supervisors should ensure       22      As LS, do you ensure that the CoCo assesses                                                                            The FME is not   if yes                            if no
                should exist in the different areas and entities within the Group.     that the CoCo assesses whether               the existence of clear lines of responsibilities in                                                                    a lead
                                                                                       there are clear lines of                     the different areas and entities within the                                                                            supervisor of
                Principle 7:                                                           responsibilities within the                  Group?                                                                                                                 any insurance
                The Colleges of Supervisors provide an efficient platform for the      insurance group.                                                                                                                                                    group.
                gathering and dissemination of relevant or essential information in                                                                                                                                                NC
                going concern and emergency situations, developing a common
                understanding of the risk profile of the Group, achieving
                coordination of supervisory review and risk assessment at Group
                level as well as establishing supervisory plans for the mitigation of
                risks at Group level.

                Guideline article 4.4:                                               For every meeting the lead          23         As LS, do you include an assessment of the                                                                             The FME is not   if yes                            if no
                To ensure an efficient process, the papers submitted to the CoCo     supervisor should provide all                  overall standard of corporate governance within                                                                        a lead
                members ahead of a meeting should include the Lead Supervisors´      CoCo members with an                           the Group into the papers submitted to the CoCo                                                NC                      supervisor of
                assessment of the overall standard of corporate governance within    assessment of the overall                      members ahead of the meeting?                                                                                          any insurance
                the Group.                                                           standard of corporate governance                                                                                                                                      group.
                                                                                     in the group.
4.5. Capital    Guideline article 4.5:                                               (1) A CoCo should consider the      24         Q1: As LS, do you ensure that the CoCos               What do you consider as                                          The FME is not   if yes to 24.1                    if no to 24.1
                The CoCo should consider different aspects of the capital available  different aspects of the capital               consider different aspects of the capital             different aspects of the capital         NC                      a lead           and 24.2                          or 24.2
                to the Group as a whole and to the different undertakings within the available to the Group as a whole              available to the Group as a whole?                    available?                                                       supervisor of
                Group.                                                               and (2) to the different                       Q2: As LS, do you ensure that the CoCos                                                                                any FME is not
                                                                                                                                                                                                                                                           The insurance
                                                                                     undertakings within the Group. It              consider different aspects of the capital                                                                              a lead
                Principle 10:                                                        is lead supervisors‟ responsibility            available to the different undertakings within                                                                         supervisor of
                Within the College of supervisors, the supervisors review and        to ensure that the CoCos                       the Group?                                                                                     NC                      any insurance
                evaluate risks to which the group and its entities are or might be   undertake those tasks.                                                                                                                                                group.
                exposed to ensure a prospective supervision and foster early-
                warning of major risks to the extent possible.
4.6.            Guideline article 4.6:                                               In order to avoid double reporting 25          Q1: Did you within the CoCo coordinate/map            Please indicate what method                                                       if yes to 25.1                    if no to 25.1
Solvency        To facilitate the avoidance of double-reporting by the insurance     the CoCo should coordinate/map                 the reporting requirements of each Member             you used.                                NC                                       and 25.2                          or 25.2
                group, the CoCo should coordinate/map the reporting requirements the reporting requirements of                      State participating?
                of each Member State participating in the CoCo and hence agree       each Member State participating                Q2: Did you within the CoCo agree from which
                from which undertaking within the insurance group an Adjusted        and agree from which                           undertaking within the group an Adjusted
                Solvency Margin should be required. In principle, the method used    undertaking within the group an                                                                                                               NC
                                                                                                                                    Solvency Margin should be required?
                will be the compulsory one in the country where the head office is   Adjusted Solvency Margin should




61e6d672-a310-44a9-b349-1e57dee3fa0f.xls
FINAL                                                                                                                                                                          Questionnaire HP - Cocos                                                                                                                          9


4.6.
SolvencyProtocol
Helsinki
Guidelines for Coordination Committees in the Context of Supplementary Supervision as Defined by the Insurance Groups Directive (98/78/EC).
              Articles                                                                  Assessment criteria                   No   Questions                                             Guidance for comments            Answers (See guidelines for replying)                               Benchmarks
              and relevant paragraphs                                                                                                                                                                                     Your reply     Implementing Comments             Fully applied    Partially applied Not applied
                                                                                                                                                                                                                                         measures
2.1.          Guideline article 2.1: of reporting, the request for information
              In order to ease burden                                                   In order to ease the burden of     26      As LS, do you ensure that all requests for                                                                                              if yes                              if no
Members of    regarding the Group should be every insurance group Lead
              There is one CoCo for each andcoordinated through theoperating in         reporting requests for information         information regarding the Group are coordinated
the CoCo      more than one EEA-country. while information requested from one
              Supervisor/Key Coordinator,                                               regarding the Group should be              by you?
              supervisor regarding an entity under its direct supervision may be        coordinated through the LS and
              The CoCo members are representatives of the Insurance
              handled by that supervisor.                                               information from one supervisor                                                                                                         NC
              Supervisory Authorities in the Member States in which the Group           regarding an entity under its
              has undertakings, and would normally be responsible for the day-to-       direct supervision may be
              day supervision of the Group in their state.                              handled by that supervisor.

4.7. Intra    Guideline article 4.7:                                                    A CoCo should pay attention to     27      As LS, do you ensure that the CoCos pay                                                                              The FME is not     if yes                              if no
Group         Attention should be given to how entities within the Group control        the way in which an insurance              attention to how entities within the Group                                                                           a lead
Transaction   their own Intra Group Transactions.                                       group controls its own intra group         control their own Intra Group Transactions?                                                                          supervisor of
s                                                                                       transactions. It is lead                                                                                                                                        any insurance
              Principle 10:                                                             supervisors‟ responsibility to                                                                                                          NC                      group.
              Within the College of supervisors, the supervisors review and             ensure that the CoCos undertake
              evaluate risks to which the group and its entities are or might be        those tasks.
              exposed to ensure a prospective supervision and foster early-
              warning of major risks to the extent possible.
              Guideline article 4.7:                                                    A CoCo should be able to monitor 28        If you are a lead supervisor:                                                                                        The FME is not     if yes to 28.1                      if no to 28.1
              Trends should be noted – e.g – are Intra Group Transactions more          trends such as (1) whether Intra           Q1: Do the CoCos for which you are the lead                                                                          a lead             and 28.2                            or 28.2
              frequent at particular times of the year, or between particular           Group Transactions are more                supervisor monitor trends such as whether Intra                                                                      supervisor of
                                                                                                                                                                                                                                NC
              entities? How many loans may a company have or how much of the            frequent at particular times of the        Group Transactions are more frequent at                                                                              any insurance
              loan must be repaid before further loans are                              year or whether Intra Group                particular times of the year or more frequent                                                                        group.
              refused?                                                                  transactions are more frequent             between particular entities?
                                                                                        between particular entities and            Q2: As a competent authority, do you provide                                                                         FME is not a
                                                                                        (2) how many loans a company               the CoCo with the information needed to                                                                              lead supervisor
                                                                                        may have or how much of the                monitor trends such as whether Intra Group                                                   NC                      of any insurance
                                                                                        loan must be repaid before                 Transactions are more frequent at particular                                                                         group nor
                                                                                        further loans are acceptable. It is        times of the year.                                                                                                   member of
                                                                                        lead supervisors‟ responsibility to        If you are not a lead supervisor:                                                                                    CoCo. has not
                                                                                                                                                                                                                                                        There            if yes to 28.3                        if no to 28.3
                                                                                        ensure that the CoCos undertake            Q3: As a competent authority, do you provide                                                                         been such
                                                                                        those tasks. Competent                     the CoCo with the information needed to                                                                              requirement to
                                                                                                                                                                                                                                NC
                                                                                        authorities should provide the             monitor trends such as whether Intra Group                                                                           provide this
                                                                                        required information to the CoCo.          Transactions are more frequent at particular                                                                         information
                                                                                                                                   times of the year.                                                                                                   within the Cocos
              Guideline article 4.7:                                                    The CoCo should determine which 29         Q1: Did the CoCo determine which transactions                                                                        FME is not a     if yes to 29.1                        if no to 29.1
              The IGD refers to the reporting of „significant‟ transactions. There      transactions are significant for           are significant for the insurance group, taking                                                                      lead supervisor and 29.2                               or 29.2
              are differences regarding the precise meaning of „significant „in         the insurance group, taking into           into account the specific risk profile of that                                               NC                      of any insurance
              national legislation of Member States, and furthermore „significant‟      account the specific risk profile of       group?                                                                                                               group nor
              will vary from one group to another. For the supervisors and the          that group.                                                                                                                                                     member of
                                                                                                                                   Q2: Did the CoCo discuss the structure and                                                                           FME is not a
              CoCo it can be very helpful to know what management of the
                                                                                                                                   interconnection of the group in the light of the                                                                     lead supervisor
              undertakings or the Group has determined as being „significant‟.          The structure and interconnection
                                                                                                                                   potential risks resulting from transactions and                                                                      of any insurance
              Ultimately, the determination of which transactions are significant       of the group should be discussed
                                                                                                                                   the resulting level of exposures?                                                                                    group nor
              for the Group will be the responsibility of the CoCo, taking into         in the light of the potential risks
                                                                                                                                                                                                                                                        member of
              account the specific risk profile of that Group.                          resulting from transactions and
                                                                                                                                                                                                                                                        CoCo.
                                                                                        the resulting level of exposures.
              The structure and interconnection of the Group should be discussed
                                                                                                                                                                                                                                NC
              in the light of the potential risks resulting from transactions and the
              resulting level of exposures.

              Principle 4:
              When forming the College of supervisors, the involved Supervisors
              shall communicate to each other their assessment of their
              respective supervised entity‟s significance and risks for the Group
              and systemic relevance for local financial markets, and take into
              Guideline article 4.7:                                                    The lead supervisor should         30      As a LS do you ensure that the concerns raised                                                                       FME is not a     if yes                                if no
              Concerns raised by members on Intra Group Transaction-issues              provide the opportunity to discuss         by the solo supervision on Intra Group                                                                               lead supervisor
              resulting from “solo supervision” should be discussed;                    Intra Group Transactions                   Transactions are discussed and analysed?                                                     NC                      of any insurance
                                                                                        resulting from “solo supervision”.                                                                                                                              group nor
              Guideline article 4.7:                                                    If measures are taken by an      31        If you are a lead supervisor:                                                                                        member of
                                                                                                                                                                                                                                                        FME is not a     if yes to 31.1,    if yes to 31.1 ,   if no to 31.1 ,
              Measures taken by the individual competent authorities towards an         individual competent authority             Q1: For all CoCo‟s where you are the lead                                                                            lead supervisor 31.2 and 31.3       31.2 and 31.3 b    31.2 or 31.3 b
              undertaking of the insurance group regarding Intra Group                  towards an undertaking of the              supervisor, are measures taken by individual                                                                         of any insurance a
                                                                                                                                                                                                                                NC
              Transactions should be discussed and, where appropriate,                  insurance group regarding Intra            members of the CoCo´s in which you participate                                                                       group nor
              coordinated;                                                              Group Transactions this                    regarding Intra Group Transactions discussed in the                                                                  member of
                                                                                        supervisory action should (1) be           CoCo?                                                                                                                CoCo.
              Principle 8:                                                              discussed by the CoCo and (2) be           Q2: For all CoCo‟s where you are the lead                                                                            FME is not a
              The Colleges of supervisors promote harmonization of                      coordinated by the CoCo where              supervisor, are measures taken by individual                                                                         lead supervisor
              approaches and coordinates input to major supervisory decisions           appropriate.                               members of the CoCo´s in which you participate                                               NC                      of any insurance
              taken by individual authorities as far as possible and practicable,                                                  regarding Intra Group Transactions, where                                                                            group nor
              and draw their conclusions where appropriate.                             Supervisory authorities shall              appropriate, coordinated?                                                                                            member of
                                                                                        consult with each other prior to           Q3: Do you inform the CoCo of any supervisory
                                                                                        making any important decisions             actions regarding Intra Group Transactions:
                                                                                        that might affect the Group as a
                                                                                        whole, or other entities within the
                                                                                                                                   a) prior to taking the action ?                                                                                      FME is not a
                                                                                        Group.
                                                                                                                                                                                                                                NC                      lead supervisor
                                                                                                                                                                                                                                                        of any insurance
                                                                                                                                   b) as soon as possible ?                              Please add the avergare timing                                 group nor a
                                                                                                                                                                                                                                                        FME is not
                                                                                                                                                                                         to inform                              NC                      lead supervisor
                                                                                                                                                                                                                                                        of any insurance
                                                                                                                                   If you are not a lead supervisor:                                                                                    group nor        if yes to 31.4 a if yes to 31.4 b     if no to 31.4 b
                                                                                                                                   Q4: Do you inform the CoCo of any supervisory
                                                                                                                                   actions regarding Intra Group Transactions:
                                                                                                                                   a) prior to taking the action ?                                                                                      FME is not a
                                                                                                                                                                                                                                NC                      lead supervisor
                                                                                                                                                                                                                                                        of any insurance
                                                                                                                                                                                                                                                        group nor




61e6d672-a310-44a9-b349-1e57dee3fa0f.xls
FINAL                                                                                                                                         Questionnaire HP - Cocos                                                                                                                10



                                                                                                                                                                                                                                if yes to 31.4 a if yes to 31.4 b   if no to 31.4 b
Helsinki Protocol
Guidelines for Coordination Committees in the Context of Supplementary Supervision as Defined by the Insurance Groups Directive (98/78/EC).
              Articles                                                              Assessment criteria   No   Questions                               Guidance for comments            Answers (See guidelines for replying)                      Benchmarks
              and relevant paragraphs                                                                                                                                                   Your reply     Implementing Comments    Fully applied    Partially applied Not applied
                                                                                                                                                                                                       measures
2.1.          Guideline article 2.1:                                                                           b) as soon as possible ?                Please add the avergare timing
Members of    There is one CoCo for each and every insurance group operating in                                                                        to inform                              NC
the CoCo      more than one EEA-country.

              The CoCo members are representatives of the Insurance
              Supervisory Authorities in the Member States in which the Group
              has undertakings, and would normally be responsible for the day-to-
              day supervision of the Group in their state.




61e6d672-a310-44a9-b349-1e57dee3fa0f.xls

				
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