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, which features an independent diversified sales channel consisting of professionals in various fields, such as tax attorneys, certified public accountants (CPAs), professional agents, banks, and brokerages. Following the group's strategic review of its life insurance business in Japan, ING Life Japan announced in May 2009