Given the change in strategy and planned rationalization of ING's U.S. operations, we now view the six rated U.S. operating companies to be strategically important to the ING group, rather than core under our group methodology criteria. The change in implied group support has led to us lower the ratings by one notch and remove them from CreditWatch Negative. The negative outlook reflects our view of the execution risk around the new U.S. strategy and credit pressures at ING's other major operating divisions. On July 9, 2009, Standard&Poor's Ratings Services lowered its counterparty credit, financial strength, and debt ratings on ING Groep N.V.'s U.S. life insurance and funding subsidiaries and removed the ratings from CreditWatch with negative implications,
