SimˈpōzēəmDr Nathalie Aubry-Stacey, Director – Market Practice and Regulatory Policy Department, ICMA* The comments and concerns raised in the Symposium so far have helped to highlight the areas that still need to be addressed in respect of the look-through reporting requirements. In addition EIOPA’s response to the reporting public consultation published in July 2012 has added some more colour to the existing formal statements on the subject. Given that the consultation answers some of our questions we have chosen to address both in our response to the symposium. The ICMA Solvency II Working Group has read EIOPA’s updated guidelines and feedback statement with interest. We were particularly interested in comment 104 (page 19), noting that, “The template Assets D4 only requires look-through of asset category, three geographical zone and currency identification (as local or foreign), not a full look-through of investment funds as required for SCR calculation.” This is a question that the members had raised many times, and it is helpful to have clear and positive guidance from EIOPA. It would be useful at this point to receive a summary of what the QRT asset rules actually mean. There seems to be certain amount of confusion on what the look through means, how often it needs to be reported, who are exempted and what constitutes an investment fund. Working group members feel that some points have not received the full attention of EIOPA. We understand the European Authority’s view that the prudent person principle is paramount in the drafting of the reporting requirements. However we feel that a lack of clarity remains and some of the practical and compliance points raised by the participants in the symposium did not seem to resonate with EIOPA.