Competitive niche positions in Japanese market, including corporate-owned life insurance for small and midsize enterprises Potential support from the ING group Investment portfolio under pressure Business concentration risk following the halt of new sales of single premium variable annuity products Weakening strategic importance to group Japan-based ING Life Insurance Co. Ltd. (ING Life Japan; A/Negative/--) is a key subsidiary of the ING Groep N.V. (A+/Negative/A-1), a global financial services conglomerate with about ¥168 trillion in gross assets as of December 2008. ING Life has developed competitive niche positions, focusing mainly on two insurance market segments: corporate-owned life insurance (COLI) products for small and midsize enterprises (SMEs), and variable annuity products for wealthy individuals. The insurer operates under a well-defined strategy,