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 life insurance (COLI) products, and wealthy individuals for variable annuity products. The insurer operates under a well-defined strategy, which features an independent diversified sales channel that consists of professionals in various fields, such as tax attorneys, certified public accountants (CPAs), professional agents, banks, and brokerages. In October
