The ratings on ING Verzekeringen N.V. (INGV; A-/Negative/A-2) and the consolidated insurance operations--collectively ING's insurance operations--reflect the insurance group's strong local competitive positions across a number of markets, highly diverse profile, and flexibility to manage capital adequacy and liquidity across the ING Group. These positive factors are partially offset by continued pressure on capital adequacy because of investment risk exposures. Earnings also remain constrained by both the difficult operating environment and initiatives to reduce asset risk. Standard&Poor's Ratings Services considers ING's insurance operations as "not strategically important" under our group rating methodology; under the restructuring plan ING Groep N.V. (ING; A/Stable/A-1) agreed with the European Commission, it took the strategic decision to divest its insurance operations before the
