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No. 20 of 2016 Determinations/Financial (Other) as made
This instrument determines Reporting Standard LOLRS 800.2 Claim Data: Public and Product Liability and Professional Indemnity Insurance.
Administered by: Treasury
Registered 09 Sep 2016
Tabling HistoryDate
Tabled HR13-Sep-2016
Tabled Senate13-Sep-2016

Financial Sector (Collection of Data) (reporting standard) determination No. 20 of 2016

Reporting Standard LOLRS 800.2 Claim Data: Public and Product Liability and Professional Indemnity Insurance

Financial Sector (Collection of Data) Act 2001

 

I, Steve Davies, delegate of APRA, under paragraph 13(1)(a) of the Financial Sector (Collection of Data) Act 2001 (the Act) and subsection 33(3) of the Acts Interpretation Act 1901:

 

(a)           REVOKE Financial Sector (Collection of Data) (reporting standard) determination No. 61 of 2006, including Reporting Standard LOLRS 800.2 Claim Data: Public and Product Liability and Professional Indemnity Insurance made under that Determination; and

 

(b)          DETERMINE Reporting Standard LOLRS 800.2 Claim Data: Public and Product Liability and Professional Indemnity Insurance, in the form set out in the Schedule, which applies to Lloyd’s within the meaning of the Insurance Act 1973.

 

Under section 15 of the Act, I DECLARE that the reporting standard shall begin to apply to Lloyd’s, and the revoked reporting standard shall cease to apply, upon the date of registration of this instrument on the Federal Register of Legislation.

 

This instrument commences upon registration on the Federal Register of Legislation.

 

Dated: 6 September 2016

 

[Signed]

 

 

Steve Davies

General Manager

Statistics Division

 

Interpretation

In this Determination:

APRA means the Australian Prudential Regulation Authority.

Schedule

 

Reporting Standard LOLRS 800.2 Claim Data: Public and Product Liability and Professional Indemnity Insurance comprises the 15 pages commencing on the following page.


 

 

 

 

Reporting Standard LOLRS 800.2

 

Claim Data: Public and Product Liability and Professional Indemnity Insurance

 

Objective of this reporting standard

This reporting standard is made under section 13 of the Financial Sector (Collection of Data) Act 2001.  It requires Lloyd’s to provide APRA with information in respect of claims made on certain on public liability, product liability and professional indemnity policies, and facility business, covering similar risks, during a reporting period. 

 

Reporting requirements 

1.             If, at any time during a reporting period covered by paragraph 2: 

(a)           a person makes a reportable claim on a Lloyd’s underwriter; or

(b)          a reportable claim originally made on a Lloyd’s underwriter before the start of the reporting period has not been settled or is reopened;

Lloyd’s must report on the claim, in accordance with the Data Specifications, by the time in paragraph 3. 

Note: reportable claim is defined in paragraph 14.

2.             For the purposes of the paragraph 1, the reporting periods are the six month period beginning on 1 January 2016 and ending on 30 June 2016 and each successive 6 month period (ending on a 31 December or a 30 June) after that.  

3.             A report required by paragraph 1 must be provided:

(a)           if the reporting period ends on 30 June – by no later than the 31 October next following the end of the reporting period; or

(b)          if the reporting period ends on 31 December – by no later than the 30 April next following the end of the reporting period, 

 

or such later time as APRA may determine in writing.  APRA may determine a later time in writing in relation to the whole of a report, or in relation to a report to the extent that it relates to a particular class of Lloyd’s underwriters, or in relation to a report to the extent that it relates to one or more Lloyd’s underwriters named in the determination (to the intent that APRA may permit the late submission of part of the report).

Variation of reporting periods

4.             APRA may, by notice in writing, determine that to the extent that reports required under this reporting standard will relate to a Lloyd’s underwriter with an accounting financial year that does not end on 30 June, the part of each such report relating to that underwriter may be provided in respect of reporting periods based on the underwriter’s own accounting financial year.  

5.             APRA may, by notice in writing, change the reporting periods for Lloyd’s to require it to provide reports under this reporting standard: 

(a)           more frequently (APRA may require this when, having regard to the particular circumstances of the Lloyd’s underwriters, APRA considers it necessary or desirable to obtain information more frequently for the purposes of the prudential supervision of the Lloyd’s underwriters); or 

(b)          less frequently  (APRA may do so when, having regard to the particular circumstances of the Lloyd’s underwriters and the extent to which they requires prudential supervision, and other relevant considerations, it is unnecessary to require Lloyd’s to provide the information on a 6 monthly basis).   

6.             If APRA changes a reporting period under paragraph 4 or 5 in relation to a report or part of a report, the report (or, where applicable, the part of the report) required under this reporting standard in respect of the changed period must be provided by no later than the last day of the second month after the end of the changed period or such later time as APRA may determine in writing.   

Method of submission

7.             Reports required by this reporting standard must be rendered in comma separated values (CSV) format in accordance with the Data Specifications, and must be provided either electronically through the web site www.ncpd.apra.gov.au, by logging on using the relevant customer identification number and password provided by Fujitsu Australia (as agent of APRA), and following the instructions on that web site.

8.             Despite paragraph 7, APRA may, in writing, make either or both of the following determinations:

(a)           a determination that reports required by this reporting standard must be provided in accordance with alternative information technology requirements specified by APRA in the determination; and

(b)          a determination that reports required by this reporting standard must be provided to APRA or an agent of APRA at an alternative address in accordance with requirements specified in the determination.

Authorisation

9.             Reports provided by Lloyd’s in accordance with this reporting standard must be the product of processes and controls developed by Lloyd’s for the internal review and authorisation of the information contained in the reports.  

Note: Lloyd’s General Representative in Australia must ensure that an appropriate set of policies and procedures is in place for the authorisation of data provided to APRA.

10.         Fujitsu Australia (as agent of APRA) will provide Lloyd’s with a customer identification number.  If Lloyd’s proposes to submit reports required by this reporting standard using the method in paragraph 7 (i.e. via the website), Lloyd’s must apply for a password by viewing the web page referred to in paragraph 7, quoting Lloyd’s customer identification number and following the instructions for applying for a password on that page.  Fujitsu Australia will advise Lloyd’s General Representative in Australia of the password for Lloyd’s.  When a report is provided using the method in paragraph 7, Lloyd’s will be required to quote its customer identification number and password.  Upon successful validation of the customer identification and password a secure session will be created and the report will be encrypted before transmission.

11.         Despite paragraph 10, or where APRA has made a determination under subparagraph 8(a) or (b) specifying an alternate method of submission, APRA may also determine in writing that: 

(a)           a specified person (who need not be Lloyd’s General Representative in Australia or agent); or

(b)          a person holding a specified position (who need not be Lloyd’s General Representative in Australia or agent); or

(c)           a person authorised by Lloyd’s to use Lloyd’s customer identification number and password, 

may, or must, authorise (in a manner specified) information provided by Lloyd’s under this reporting standard.

Minor alterations to forms and instructions

12.         APRA may: 

(a)           make minor variations to the Data Specifications (either generally, or in relation to a class of Lloyd’s underwriters, or in relation to one or more named Lloyd’s underwriters) to correct technical, programming or logical errors, inconsistencies or anomalies; 

(b)          vary, omit or substitute (either generally, or in relation to a class of Lloyd’s underwriters, or in relation to one or more named Lloyd’s underwriters) an occupation code or description in Appendix C to the Data Specifications, if APRA forms the view that the existing code or description is inappropriate having regard to the circumstances or business of Lloyd’s and any other relevant considerations; or

(c)           vary, omit or substitute (either generally, or in relation to a class of Lloyd’s underwriters, or in relation to a one or more named Lloyd’s underwriters) a specification in a Table in the Data Specifications, if APRA forms the view that the specification is inappropriate having regard to the circumstances or business of Lloyd’s underwriters and any other relevant considerations.

13.         If APRA makes such a variation it must notify Lloyd’s in writing.

Interpretation

14.         In this reporting standard:

agent of APRA means a person appointed under s 47 of the Australian Prudential Regulation Authority Act 1998 to receive data on behalf of APRA.

APRA means the Australian Prudential Regulation Authority established under the Australian Prudential Regulation Authority Act 1998.

Data Specifications means the Data Specifications in the Schedule.

facility business means business that is closed by bordereau and for which the relevant Lloyd’s underwriter does not receive individual policy or claims data from the facility manager, and includes business undertaken through an underwriting pool or joint venture arrangement.

Fujitsu Australia means Fujitsu Australia Limited ABN 19 001 011 427.

Lloyd’s has the meaning in the Insurance Act 1973.

Lloyd’s General Representative in Australia means the employee of Lloyd’s or Lloyd’s Australia Ltd who holds the position of Lloyd’s General Representative in Australia, or performs the functions and duties described by that title.

Lloyd’s underwriter has the meaning in the Insurance Act 1973.

product liability insurance includes policies that provide for compensation for loss and or injury caused by, or as a result of, the use of goods.

professional indemnity insurance includes:

(a)           insurance that provides cover for a professional for actions taken against that professional in tort, contract or under statute law in respect of advice or services provided as part of their professional practice, including cover in respect of damages and legal expenses;

(b)          directors’ and officers’ liability insurance and legal expense insurance; and

(c)           medical indemnity insurance.

public liability insurance includes:

(a)           insurance covering legal liability to the public in respect of bodily injury or property damage arising out of the operation of the insured’s business; and

(b)          insurance in respect of environmental clean-up costs resulting from pollution where not covered by Fire and Industrial Special Risk policies.

reportable claim means a claim made under a policy of product liability insurance, professional indemnity insurance or public liability insurance that was not finalised or settled by 1 January 2003, not being a claim that relates to:

(a)           reinsurance or retrocession cover; or

(b)          marine insurance; or

(c)           domestic householder’s or owner’s insurance, or tenant’s liability insurance, sold in conjunction with a building or contents policy; or

(d)          an event that could neither occur in Australia nor in relation to an insured resident of Australia.

15.         For the purposes of paragraphs 3 and 6, where a report must be provided no later than a particular date, Lloyd’s is required to ensure that the report is received by the person to whom it must be provided (whether APRA or an agent of APRA) no later than that date.


Schedule

 

 

Data specifications for individual claims for public and product liability and professional indemnity Insurance

 

Overview  

 

These specifications have been prepared for the purpose of defining the claim information required to be submitted by general insurers in respect of public and product liability and professional indemnity insurance.  This information will contribute to a National Claims and Policy Database (NCPD) in respect of these classes of insurance.  The intention is to create a database that holds information in respect of claims and policies for public and product liability and professional indemnity on a national basis.      

Details of requirements in relation to reporting periods, method of submission and authorisation are set out in the reporting standard.  The data submitted by each general insurer will be validated by APRA each reporting period. The data validation to be performed is outlined in Appendix A.

Record Layouts and Field Specifications 

Claim Data

Claims Data

Data Item

Public          &

Products

Professional Risk

Field type1

1*

Insurer code

M

M

6a

2*

Record type 

M

M

1a

3

Status at end of Reporting Period

M

M

1a

4*

Month of End of Reporting Period

M

M

8n

5*

Class of Business

M

M

2a

6*

Policy Number

M

M

30a/n

7*

Risk Number

M

M

30a/n

8*

Claim Number

M

M

30a/n

9*

Date of Loss

M

O

8n

10

Date of Report

M

M

8n

11

Date Finalised

M

M

8n

12

Jurisdiction of Claim

O

O

3a

13

Deductible/Excess

O

O

12n

14

General Nature of Loss

O

O

1a

15

Cause of Loss

O

O

3a

16

Body Functions or Structures Affected

O

O

1a

17

Severity of Loss

O

O

1a&1n

18

Litigation Status

O

O

1a

19

Gross Payments in the Reporting Period

M

M

12n

20

Gross Payments to Date 

M

M

12n

21

Gross Case Estimate at Start of Reporting Period

M

M

12n

22

Gross Case Estimate at End of Reporting Period

M

M

12n

23

Gross Third Party Recoveries Received 

O

O

12n

24

Gross Third Party Recoveries Outstanding

O

O

12n

25.1

Past economic loss

O

O

12n

25.2

Future economic loss

O

O

12n

25.3

Past medical, hospital, caring and related services

O

O

12n

25.4

Future medical, hospital and related services

O

O

12n

25.5

Future caring services

O

O

12n

25.6

General damages

O

O

12n

25.7

Interest

O

O

12n

25.8

Plaintiff legal costs

O

O

12n

25.9

Defendant legal costs

O

O

12n

25.10

Investigation costs

O

O

12n

25.11

Other

O

O

12n

 

1Date – preference for date is DDMMYYYY, no delimiter.

Key:

M – mandatory field on all records from 1 July 2004

O – optional field a – alpha

n - numeric

* Fields so indicated, as a combination, must be unique for each reporting period.

 

Claims Record Data Field Definitions

1.         Insurer code 

This will be provided by APRA when advised of the method of delivery of the data.

2.         Record type  

       C for Claims Record

3.       Status at End of Reporting Period

           C for Current

           F for Finalised

           For claims that have been reopened, code a “C”

           S for Structured Settlement

4.       Month of End of Reporting Period 

The data will relate to a six month period.  Code the last day of this period in this field as DDMMYYYY, e.g. insert code 30062003 for data relating to the six months ending 30 June 2003. 

5.       Class of Business

           PL = Public & Product

           PI = Professional Risk

6.       Policy Number            

The unique market reference field allocated by the Lloyd’s broker.  This information is only used for cross-referencing by APRA – it will not be published except in any individual data reports prepared for the insurer concerned. 

Where individual claims data is being provided but its associated policy data is being provided in aggregate form in the facility data file, the facility number should be used as the policy number for the claim.

7.       Risk Number  

The broker reference field used to sub-divide accounting entries into different countries.

8.       Claim Number

A unique identifier of a claim.  This information is only used for cross-referencing by APRA – it will not be published except in any individual data reports prepared for the insurer concerned.  

9.       Date of Loss 

Code date on which the incident giving rise to the claim is believed to have occurred in this field as DDMMYYYY.  In cases where the actual date of loss is not known or relates to a period of time, then use the date when the claim was made or the first advice was given to Lloyd’s syndicates.

10. Date of Report               

Code date when claim was first advised (not processed) to the Lloyd’s syndicate as DDMMYYYY.

11. Date Finalised                

Code date when claim is finalised as DDMMYYYY.  This field should only be completed when all payments to the claimant(s) and any third party suppliers are believed to have been made and all recoveries expected from third parties (ignoring reinsurers) have been received.  Note that a claim may be recorded as finalised even if recoveries from reinsurers have not been received.  

If the status of the claim is Finalised, this field is mandatory.  Where the claim is not finalised this field is “blank”.

12. Jurisdiction of Claim

This is the state (ACT, NSW, NT, QLD, SA, TAS, VIC or WA) where the claim has been decided by a court judgement. If the claim is decided in a federal court, input the state where the claim was heard. However, if the claim is settled out of court, then input the state where the claim was settled, i.e. the state in which the claimant’s payment is paid.

Where this information is not available, enter a hyphen (“-“).

13. Deductible/Excess

Total of all deductibles or excesses applied to this claim in whole dollars converted to A$ using end of processing month rates of exchange.  This may differ from the amount shown in field 20 on the related exposure record.

Where this information is not available, enter a hyphen (“-“).

14. General Nature of Loss           

Code the general nature of loss as

           P = Property damage only

           B = Bodily injury or death

           L = Both property damage and bodily injury

           F = Financial loss only (no physical damage or bodily injury)

           X = Both bodily injury and financial loss

           Y = Both property damage and financial loss

           Z = Property damage, bodily injury and financial loss

Code as a hyphen (“-“) if unknown

If a claim is comprised of more than one general nature of loss field type (i.e. P (property damage) and B (bodily injury)), then a claim may only be coded as L, X, Y or Z if the relevant component is greater than 15% of the claim amount.

Where this information is not available, enter a hyphen (“-“).

15. Cause of loss 

Code one of the causes shown in the following table to the claim.  The most significant contributing factor should be identified.  

Where this information is not available, enter a hyphen (“-“).

 

APRA

Code

Claim Type – Public & Products Liability

Current ISA Code(s)

 (for information only)

ABM

Abuse/molestation

L12

ANM

Animal bite/attack/impact

L88, L16, L62

ASB

Asbestos/Dust Diseases

L14

CAT

Catastrophe, e.g. Cyclone, earthquake

 

CUS

Care/custody/control

L50

COL

Collapse of building/structure/subsidence/landslide/weakening and or removal of supports/rusting/oxidation/discoloration including concrete cancer

L18, L42, L86, L40

DFM

Defamation/slander

L53

DSC

Discrimination/harassment

L54

ELC

Electrocution

L21

ENV

Environmental contamination or pollution/spray/drift/ other contamination/exposure to or contact with substance/

Not mould or asbestos

L72, L80, L19, L24

EQB

Equipment breakdown and accidental breakage

L22, L11

EXP

Explosion and/or vibration/exposure to sudden or long-term  sound or noise/excavation/drilling damage

L23, L56, L43, L65

NEG

Failed or injurious treatment by practitioner or consultant, or negligent advice

L29, L69

FLL

Fall including from height and slip & fall

L25, L41

FPW

Faulty product/faulty workmanship

L51, L59

FIR

Fire including welding

L27, L87

IMP

Impact or damage by object/vehicle/person, including physical assault/trapped by machinery or equipment 

L30, L44, L66, L37, L83

LSL

Lease liabilities

L64

LFT

Lifting, carrying or putting down objects/machinery use/repetitive or overuse injury

L63, L66, L77

 

MLD

Mould

L89

OTH

Other non-financial loss

L48

OFN

Other financial loss

L26

WTR

Water

L46

WKR

Worker to worker injury

L47

 

Table 2

 

APRA

Code

Claim Type – Professional Risk 

 

Non-performance or improper, inappropriate,  inadequate, incorrect, incomplete, inaccurate, untimely provision of : 

AA

Advice

DA

Documentation/ administration

SI

Supervision / inspection

DS

Design / specification

PM

Project management

TE

Testing

DI

Diagnosis

TR

Treatment

PR

Procedural

ME

Medication

IC

Infection control / prevention

AE

Anaesthetic

BL

Blood Products

CO

Consent (incl. no valid consent, failure to warn, acting against patient’s 

APRA

Code

Claim Type – Professional Risk 

 

wishes)

SE

Services other than specified above

EQ

Faulty and/or inadequate / inappropriate / inaccurate / contaminated equipment  and/or premises

IP

Breach of intellectual property rights

DE

Defamation

CI

Conflict of interest

BC

Breach of confidentiality

BT

Breach of trust / fiduciary duties

UD

Unfair dismissal

LD

Loss of documents

FR

Fraud & dishonesty.  Fidelity

MI

Misleading and/or deceptive advice/conduct (specifically section(s) of federal Trade Practices Act, state Fair Trading Acts and the like)

AB

Assault /abuse / mistreatment

HA

Harassment / discrimination

SH

Sexual harassment

IN

Insolvency

LE

Legal expense coverage (disciplinary enquiries, investigations, inquests and the like)

IT

Improper trading / collusive practices /unconscionable conduct

OR

Other

 

Table 3

16. Body Functions of Structures Affected

Code the most significant body function or structure affecting the claimant as known at the end of the reporting period.

APRA Code

Body Functions or Structures Affected

C

Cardiovascular, Haematological, Immunological and Respiratory

D

Death

E

Digestive, Metabolic and Endocrine Systems 

G

Genitourinary and Reproductive

M

Mental or Nervous System 

N

Neuromusculoskeletal and Movement-Related

P

Sensory, Pain, Eye, Ear and Related Structures 

S

Skin and Related Structures

V

Voice and Speech

 

Table 4

Where this information is not available, enter a hyphen (“-”).

17. Severity of loss

Code the severity of the loss underlying the claim for all claims involving bodily injury where claim item 14 (General Nature of Loss) contains a bodily injury component.

APRA code

Severity of loss [acute bodily injury claims only]

L1

Minor or mild injury to soft tissue; minor lacerations; bruising

L2

Minor or simple fractures; larger lacerations

M1

Moderate injury usually involving nerve or tissue damage

APRA code

Severity of loss [acute bodily injury claims only]

M2

Serious injury involving loss of tissue, internal bleeding, ruptured tissue or organs

S1

Major injury involving brain injury likely to lead to permanent impairment

S2

Major injury involving spinal cord injury likely to lead to permanent impairment

S3

Quadriplegia

S4

Paraplegia

S5

Other major injury leading to a disability that is likely to permanently reduce the earning capacity or activity in the community of the claimant 

 

Table 5

Where this information is not available, enter a hyphen (“-“).

18. Litigation Status

Extent to which case has proceeded through the legal system

APRA Code

Litigation Status

O

Claim is not litigated

N

Plaintiff does not have legal representation

U

Plaintiff has legal representation but the claim has not been resolved.

L

Plaintiff has obtained legal advice but settlement was reached by negotiation (whether court proceedings were commenced or subsequent to a judgement but before an appeal court determination)

V

Case was settled by court judgement (whether lower court or appeal court) and defendant paid judgement amount (i.e. either case was not appealed or appeal was not upheld)

W

Plaintiff has legal representation and elects to withdraw the claim.

X

Plaintiff has legal representation, but the case is not awarded in plaintiff’s favour

 

Table 6

Where this information is not available, enter a hyphen (“-“).

19. Gross Payments in the Reporting Period              

The amount of the Lloyd’s share of payments made since the last reporting period, net of GST in whole dollars, no decimal point and converted to A$ using end of processing month rates of exchange. Includes payments made to claimant and to third party service providers (medical, legal, investigation) that are attributed to the claim.  

20. Gross Payments to Date         

The amount of Lloyd’s share of payments made on this claim since the claim was first reported, net of GST in whole dollars, no decimal point and converted to A$ using end of processing month rates of exchange. Includes payments made to claimant and to third-party service providers (medical, legal, investigation) that are attributed to the claim.  

21. Gross Case Estimate at Start of Reporting Period          

Total of Lloyd’s share of all payments expected to be made in future to the claimant(s) and third party providers at the start of the reporting period, net of GST in whole dollars, no decimal point and converted to A$ using end of processing month rates of exchange. Equals field 22 on the corresponding claim record that was submitted for the previous reporting period. Zero if this claim was first reported in the current reporting period.  

22. Gross Case Estimate at End of Reporting Period            

Total of Lloyd’s share of all payments expected to be made in future to the claimant(s) and third party providers at the end of the reporting period, net of GST in whole dollars, no decimal point and converted to A$ using end of processing month rates of exchange. 

23. Gross Third Party Recoveries Received                

Total of Lloyd’s share of all amounts that have been received to date from third parties in respect of the claim, net of GST in whole dollars, no decimal point and converted to A$ using end of processing month rates of exchange. Excludes any amounts that have been received under reinsurance contracts.  Where this information is not available, enter a hyphen (“-“).

24. Gross Third Party Recoveries Outstanding          

Total of Lloyd’s share of all amounts that are expected to be received after the end of the reporting period from third parties in respect of the claim, net of GST in whole dollars, no decimal point and converted to A$ using end of processing month rates of exchange. Excludes any amounts expected to be received under reinsurance contracts.

Where this information is not available, enter a hyphen (“-“).

25. Gross Claim Payments by Head of Damage before Third Party Recoveries (This field is not used)

A breakdown of Lloyd’s share of the total settlement amount (converted to A$ using end of processing month rates of exchange) into the following heads of damage is required for finalised claims only. The total of items 25.1 to 25.11 must equal item 20 – Gross Payments to Date, with any rounding difference included in item 23.11 (Other). 

A finalised claim is one where field 11 (date finalised) has been recorded and field 22 (gross case estimate at end of reporting period) is zero.

Where this information is not available, enter a hyphen (“-“).

25.1 Past economic loss

25.2 Future economic loss

25.3 Past medical, hospital, caring and related services

25.4 Future medical, hospital and related services

25.5 Future caring services

25.6 General damages

25.7 Interest

25.8 Plaintiff legal costs

25.9 Defendant legal costs

25.10 Investigation costs

25.11 Other

Appendix A: Data Validation

The individual claim data submitted by Lloyd’s will be validated by APRA as follows:

1.             Gross case estimate at the start of the current reporting period (claim field 19) will be compared with gross case estimate at the end of the previous reporting period (claim field 20) for each claim with a date of report prior to the start of the current reporting period.  Any discrepancy must be explained.

2.             Gross claim payments submitted in information provided by Lloyd’s under Lloyd’s Security Trust Fund Determination No 1, less the gross payments received for all facilities, is expected to reconcile to within 5% of the gross payments for each accident year calculated from the individual claim records submitted.  Discrepancies in the most recent accident years will be compared with the amount of payments made for all facilities. 

While it is appreciated that more extensive reconciliation could be attempted, this could require significant changes to the existing reporting requirements to APRA or the submission of other information (such as management accounts) from insurers that would not be in standard formats.  

APRA will expect that where Lloyd’s needs to demonstrate the reason for a discrepancy between the individual records submitted to the database and its aggregate data reported to APRA in the above forms, Lloyd’s will share such additional reports with APRA as required.