Strategically important subsidiary of the ING Group Strong position in the small and midsize enterprise (SME) market and the variable annuity market of Japan Very strong capitalization General account's investment portfolio comprised of sound assets Higher earnings volatility due to intensified competition in the variable annuity market Japan-based ING Life Insurance Co. Ltd. (AA-/Stable/--) is a key subsidiary of the ING Groep N.V. (AA-/Stable/A-1+), a global financial services conglomerate with about ¥19.2 trillion in gross assets as of December 2006. Japan is considered one of the most important insurance markets for the group, particularly given its market potential for asset accumulation-type products. ING Life has developed competitive niche positions, focusing mainly on two insurance market segments: SME owners for corporate-owned