Bond ING Groep 0% ( XS2322308359 ) in USD

ING Groep

100 % ⇌

Netherlands

XS2322308359 ( in USD )

31/03/2036

Prospectus brochure of the bond ING Bank XS2322308359 en USD 0%, maturity 31/03/2036

1 000 000 USD

17 000 000 USD

ING Bank is a multinational banking and financial services corporation headquartered in Amsterdam, offering a wide range of banking products and services to individuals and businesses globally.

This financial analysis details a specific bond issuance, identified by ISIN XS2322308359, originating from ING Bank, a prominent global financial institution headquartered in the Netherlands and recognized for its comprehensive banking, investment, and asset management services catering to a diverse client base including individuals, small and medium-sized enterprises, and large corporations worldwide. The bond, categorized as a debt instrument, is currently quoted at 100% of its nominal value on the market and is denominated in USD. Notably, it features a 0% interest rate, indicating its structure as a zero-coupon bond where investors do not receive periodic interest payments. The total size of this particular issuance stands at 17,000,000 USD, with a minimum subscription tranche established at 1,000,000 USD. This instrument carries a long-term maturity date of March 31, 2036, and while structured as a zero-coupon bond, a payment frequency of two (implying semi-annual) is specified, typically relevant for yield calculations or underlying structural characteristics rather than actual cash distributions.

Dated 25 March 2022

ING BANK N.V.
(A limited liability company (naamloze vennootschap) incorporated in The Netherlands with its statutory seat in
Amsterdam)

REGISTRATION DOCUMENT
This document constitutes a registration document, as supplemented from time to time (the "Registration
Document") for the purpose of Regulation (EU) 2017/1129, as amended (the "Prospectus Regulation") in relation
to ING Bank N.V. (the "Issuer" or "ING Bank") and has been drawn up in accordance with Annex 6 of the
Commission Delegated Regulation (EU) 2019/980, as amended.
This Registration Document has been approved by the Netherlands Authority for the Financial Markets (the "AFM")
on 25 March 2022 in its capacity as competent authority pursuant to Article 20 of the Prospectus Regulation. Together
with any securities note for non-equity securities, as supplemented or replaced from time to time (each a "Securities
Note") of the Issuer, in each case, this Registration Document forms part of any prospectus of the Issuer consisting
of separate documents within the meaning of the Prospectus Regulation in respect of the relevant securities (this
Registration Document together with the respective Securities Note, in each case the "Prospectus"). The AFM only
approves this Registration Document as meeting the standards of completeness, comprehensibility and
consistency imposed by the Prospectus Regulation. Such approval should not be considered as an endorsement
of the Issuer that is the subject of this Registration Document.
Investors should have regard to the risk factors described under the section headed "Risk Factors" in this Registration
Document. This Registration Document does not describe all of the risks regarding the Issuer, but the Issuer believes
that all material and specific risks relating to it have been described.

TABLE OF CONTENTS
Page
TABLE OF CONTENTS ................................................................................................................................... 2
RISK FACTORS ................................................................................................................................................ 3
IMPORTANT NOTICES ..................................................................................................................................28
DOCUMENTS INCORPORATED BY REFERENCE .....................................................................................30
DESCRIPTION OF ING BANK N.V. ..............................................................................................................33
SELECTED FINANCIAL INFORMATION ....................................................................................................58
OPERATING AND FINANCIAL REVIEW AND PROSPECTS ....................................................................61
SELECTED STATISTICAL INFORMATION .................................................................................................83
GENERAL INFORMATION ............................................................................................................................93

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RISK FACTORS
Any of the risks described below could have a material adverse effect on the business activities, financial
condition, results and prospects of ING. The Issuer may face a number of the risks described below
simultaneously and, where a cross-reference to another risk is included, the risks described below may be
interdependent. While the risk factors below have been divided into categories, some risk factors could belong
in more than one category and investors should carefully consider all of the risk factors set out in this section.
Additional risks of which the Issuer is not presently aware, or that are, as at the date of this Registration
Document, viewed as immaterial, could also affect the business operations of ING and have a material adverse
effect on ING's business activities, financial condition, results and prospects. The market price of ING shares
or other securities could decline due to any of those risks including the risks described below, and investors
could lose all or part of their investments.
Although the most material risk factors have been presented first within each category, the order in which the
remaining risk factors are presented is not necessarily an indication of the likelihood of the risks actually
materialising, of the potential significance of the risks or of the scope of any potential negative impact to the
Issuer's business, results, financial condition and prospects.
ING Group is a holding company whose principal asset is its investments in the capital stock of ING Bank, its
primary banking subsidiary. As a result, the risks applicable to ING Bank are substantially similar to those
impacting ING Group.
1
Risks related to financial conditions, market environment and general economic trends
ING's revenues and earnings are affected by the volatility and strength of the economic, business, liquidity,
funding and capital markets environments of the various geographic regions in which it conducts business,
as well as by changes in customer behaviour in these regions, and an adverse change in any one region
could have an impact on its business, results and financial condition.
Because ING is a multinational banking and financial services corporation, with a global presence and serving
around 38 million customers, corporate clients and financial institutions in over 40 countries, ING's business,
results and financial condition may be significantly impacted by turmoil and volatility in the worldwide
financial markets or in the particular geographic areas in which the Issuer operates. In Retail Banking, ING's
products include savings, payments, investments, loans and mortgages in most of the Issuer's Retail Banking
markets. In Wholesale Banking, the Issuer provides specialised lending, tailored corporate finance, debt and
equity market solutions, payments & cash management, trade and treasury services. As a result, negative
developments in financial markets and/or countries or regions in which the Issuer operates have in the past had
and may in the future have a material adverse impact on its business, results and financial condition, including
as a result of the potential consequences listed below.
Factors such as interest rates, securities prices, credit spreads, liquidity spreads, exchange rates, consumer
spending, changes in customer behaviour, climate change, business investment, real estate values and private
equity valuations, government spending, inflation or deflation, the volatility and strength of the capital markets,
political events and trends, supply chain disruptions, shortages, terrorism, pandemics and epidemics (such as
Covid-19, as described in greater detail below in the interdependent risk factor `ING's business, results and
financial condition have been, and likely will continue to be, adversely affected by the Covid-19 pandemic') or
other widespread health emergencies all impact the business and economic environment and, ultimately, the
Issuer's solvency, liquidity and the amount and profitability of business the Issuer conducts in a specific
geographic region. Certain of these risks are often experienced globally as well as in specific geographic regions
and are described in greater detail below in the interdependent risk factors `Interest rate volatility and other
interest rate changes may adversely affect the Issuer's business, results and financial condition', `Inflation

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and deflation may negatively affect the Issuer's business, results and financial condition', `Market conditions,
including those observed over the past few years, and the application of IFRS 9 may increase the risk of loans
being impaired and have a negative effect on the Issuer's results and financial condition' and `Continued risk
of political instability and fiscal uncertainty in Europe and the United States, as well as ongoing volatility in
the financial markets and the economy generally have adversely affected, and may continue to adversely affect,
the Issuer's business, results and financial condition'. All of these are factors in local and regional economies
as well as in the global economy, and the Issuer may be affected by changes in any one of these factors in any
one country or region, and more if more of these factors occur simultaneously and/or in multiple countries or
regions or on a global scale.
In case one or more of the factors mentioned above adversely affects the profitability of the Issuer's business,
this might also result, among other things, in the following:
·
inadequate reserves or provisions, in relation to which losses could ultimately be realised through profit
and loss and shareholders' equity;
·
the write-down of tax assets impacting net results and/or equity;
·
impairment expenses related to goodwill and other intangible assets, impacting net result and equity;
and/or
·
movements in risk weighted assets for the determination of required capital.
In particular, the Issuer is exposed to financial, economic, market and political conditions in the Benelux
countries and Germany, from which it derives a significant portion of its revenues in both Retail Banking and
Wholesale Banking, and which could present risks of economic downturn. Though less material, the Issuer also
derives substantial revenues in the following geographic regions: Turkey, Eastern Europe (primarily Poland
among others), Southern Europe (primarily Spain among others), East Asia (primarily Singapore among others)
and Australia. In an economic downturn affecting some or all of these jurisdictions, the Issuer expects that
higher unemployment, lower family income, lower corporate earnings, higher corporate and private debt
defaults, lower business investments and lower consumer spending would adversely affect the demand for
banking products, and that ING may need to increase its reserves and provisions, each of which may result in
overall lower earnings. The impact of the Covid-19 pandemic, as an example of an economic downturn, as well
as the substantial monetary and government measures, are still materialising and expected to continue to affect
ING's business. For more information, see the interdependent risk factor " ING's business, results and financial
condition have been, and likely will continue to be, adversely affected by the Covid-19 pandemic". ING also
has Wholesale Banking activities in both Russia and Ukraine, as well as investments in Russia, some of which
are denominated in local currency. The impact on ING's business in Russia and Ukraine, as well as the potential
regional and global economic impact of the invasion of Ukraine and related international response measures,
including sanctions, capital controls, restrictions on SWIFT access and restrictions on central bank activity, on
its broader business, including spill-over risk to the entire Wholesale Banking portfolio (e.g. commodities
financing, energy and utilities and energy-consuming clients), remain uncertain. Securities prices, real estate
values and private equity valuations may also be adversely impacted, and any such losses would be realised
through profit and loss and shareholders' equity. The Issuer also offers a number of financial products that
expose it to risks associated with fluctuations in interest rates, securities prices, corporate and private default
rates, the value of real estate assets, exchange rates and credit spreads.
For further information on ING's exposure to particular geographic areas, see Note 33 `Information on
geographical areas' in the 2021 Annual Report, which is incorporated by reference into this Registration
Document.

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ING's business, results and financial condition have been, and likely will continue to be, adversely affected
by the Covid-19 pandemic.
The Covid-19 pandemic and the related response measures introduced by various national and local
governmental authorities aimed at preventing the further spread of the disease (such as bans on public events
with over a certain number of attendees, closures of places where larger groups of people gather such as schools,
sports facilities, bars and restaurants, lockdowns, border controls and travel and other restrictions) have
disrupted the normal flow of business operations in those countries and regions where ING and its customers
and counterparties operate (such as, among others, Benelux, Germany, France, Italy, Spain, the U.K. and the
U.S.). This disruption has adversely affected, and will likely continue to adversely affect, global economic
growth, supply chains, manufacturing, tourism, consumer spending, asset prices and unemployment levels, and
has resulted in volatility and uncertainty across the global economy and financial markets, as described under
the heading `Description of ING Bank N.V. Significant Developments in 2021'. Please also refer to the
interdependent risk factor `ING's revenues and earnings are affected by the volatility and strength of the
economic, business, liquidity, funding and capital markets environments of the various geographic regions in
which it conducts business, and an adverse change in any one region could have an impact on its business,
results and financial condition' for a further description of how ING's business, results and financial condition
may be materially adversely impacted by developments in regional or global economic conditions.
In addition to the measures aimed at preventing the further spread of Covid-19, governments and central banks
around the world have also introduced measures aimed at mitigating the economic consequences of the
pandemic and related response measures, such as guarantee schemes, compensation schemes and cutting
interest rates. For example, the Dutch government has implemented economic measures aimed at protecting
jobs, households' wages and companies, e.g., by way of tax payment holidays, guarantee schemes and a
compensation scheme for heavily affected sectors in the economy. These announced measures and any
additional measures, including any payment holidays with respect to mortgages or other loans, have had and
may continue to have a significant impact on ING's customers and other counterparties.
Governments, regulators and central banks (including the ECB), have also announced that they are taking or
considering measures seeking to safeguard the stability of the financial sector, to prevent lending to the business
sector from being jeopardised and to ensure the payment system continues to function properly, as described
under the heading `Description of ING Bank N.V. Significant Developments in 2021'. As at the date of this
Registration Document, the ECB allows banks to operate below the level of capital required by the Pillar 2
Guidance, capital conservation buffer and the liquidity coverage ratio. The ECB has communicated its
commitment to extend this permission until at least the end of 2022. In March 2020, several countries also
released or reduced countercyclical buffers (CCyB), with some of these countries subsequently announcing
increases in CCyB in the second half of 2022. The ECB's recommendation to the banks that it supervises to
limit shareholder remuneration through dividends or share buy-backs expired on 30 September 2021. However,
it is not certain whether these or future Covid-19 relief measures will be extended or maintained for a sufficient
period of time, or whether such measures will be successful in mitigating the economic consequences of the
pandemic and related response measures. If the pandemic is prolonged or the actions are unsuccessful,
additional actions by governments and central banks may follow and the adverse impact on the global economy
will deepen, and ING's business, results and financial condition may be materially adversely affected.
In 2020, the Covid-19 pandemic affected all of ING's businesses, including lower or negative interest rates,
lower oil prices and credit deterioration of loans to ING's customers. These effects have also resulted in an
increase in the allowance for credit losses and impairments on non-financial assets, and reduced net interest
income due to lower interest rates. While these effects were partly offset by resilient fee and commission income
in 2020, this level of activity may not persist in future periods.

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While vaccination rates continued to increase and Covid-19 related restrictions were lifted in some jurisdictions
in the third quarter of 2021, the end of 2021 was again marked by an increasing number of Covid-19 infections.
This may result in changes in government responses and further downside risk towards macro-economic
developments, with possibly a deeper risk aversion and a delayed recovery. These developments may result in
further negative impact on ING's business, results and financial condition.
In 2021, ING also took certain measures to support customers impacted by the Covid-19 pandemic, including
payment holidays, offering credit facilities to business clients under government guarantee schemes and
providing liquidity under credit facilities to large corporate clients. As of 31 December 2021, in line with the
European Banking Association (EBA) moratoria guidelines, approximately 137,000 customers had been
granted payment holidays (down from 148,000 as of 30 September 2021 due to reimbursements and
prepayments). The total exposure of loans for these customers for which a payment holiday has been granted
amounts to 15.3 billion, of which 57% were for customers located in the Netherlands and Belgium. As of 31
December 2021, the outstanding amount of granted payment holidays not expired was 38 million. ING
recorded a net addition of 346 million to loan loss provisions in the fourth quarter of 2021, mainly as a result
of adjustments to existing Stage 3 files reflecting uncertainty in recovery scenarios and valuations in certain
asset classes and also reflecting a potential impact of higher inflation and interest rates on customers' ability to
pay and the potential impact of market uncertainty on the recovery value of certain asset classes. In 2021, ING
recorded 516 million of net additions to loan loss provisions, compared to 2,675 million in 2020. At the end
of the fourth quarter of 2021, increasing numbers of Covid-19 infections were observed and uncertainty
concerning the ongoing pandemic remained. Should these global economic conditions be prolonged or worsen,
or should the pandemic lead to additional market disruptions, ING may experience more client defaults and
further additions to loan loss provisions. In these circumstances, ING may also experience reduced client
activity and demand for its products and services, increased utilization of lending commitments and higher
credit and valuation adjustments on financial assets. In addition, persistently low interest rates for a longer
period, as well as a potential further decline in interest rates might result in further decreases in net interest
income. These factors and other consequences of the Covid-19 pandemic may materially adversely affect ING's
business, results and financial condition.
ING's capital and liquidity position may also be adversely impacted by the Covid-19 pandemic and related
response measures, including as a result of changes in future levels of savings and deposits from customers,
changes in asset quality, and the effects of government or regulatory responses to the pandemic, and may require
changes to ING's funding structure, impact ING's ability to comply with regulatory capital requirements and
adversely affect ING's cost of capital and credit rating. Any of the foregoing developments may have a material
adverse impact on ING's business, results and financial condition.
As of 31 December 2021, most of ING's staff continue to work from home, with employees in certain
jurisdictions beginning to return to ING's offices in a controlled manner, taking into account local circumstances
and any applicable government measures (including with respect to social distancing where applicable). Due to
the uncertainties relating to the future development of the Covid-19 pandemic, it is not certain when ING's
employees may be generally expected or permitted to return or to remain at ING's offices. If due to illness,
technical limitations or other restrictions in connection with the pandemic, employees are unable to work or are
not able to operate as effectively and efficiently as they did in the office, this may adversely affect ING's
business, results and financial condition.
In addition, a situation in which most or some of ING's employees continue working from home may raise
operational risks, including with respect to information security, data protection, availability of key systems and
infrastructure integrity. There is also a risk that ING will not be effective in implementing regulatory or strategic
change programmes in the current environment. The Covid-19 pandemic has led to new banking behaviour
from customers. There has been an increase in the digital behaviour of ING's customers leading to reduced

6

traffic in branches. Over 95% of its customers now interact with ING via digital channels only. Criminals are
also taking advantage of the Covid-19 pandemic to carry out financial fraud and exploitation scams, with
examples including advertising and trafficking in counterfeit medicines, offering fraudulent investment
opportunities, fundraising for fake charities and engaging in phishing schemes that prey on virus-related fears.
National authorities and international bodies (including the Financial Action Task Force) warn citizens and
businesses against impostor, investment and product scams. Although ING has organised a Covid-19 taskforce
to identify and analyse new behavioural patterns, leading to new cases of unusual transactions being reported
to the relevant authorities, new banking behaviours may result in additional Know Your Customer (KYC) risks.
If any of these risks were to materialise that may adversely affect ING's business, results and financial condition.
The duration of the pandemic and the impact of measures taken in response by governmental authorities, central
banks and other third parties, whether direct or indirect, such as by increasing sovereign debt of certain countries
which may result in increased volatility and widening credit spreads, remain uncertain. Therefore, it is difficult
to predict the extent to which ING's business, results and financial condition, as well as ING's ability to access
capital and liquidity on financial terms acceptable to ING, may be materially adversely affected.
Interest rate volatility and other interest rate changes may adversely affect the Issuer's business, results and
financial condition.
Changes in prevailing interest rates may negatively affect the Issuer's business, including the level of net interest
revenue the Issuer earns, and the levels of deposits and the demand for loans. A sustained increase in the
inflation rate in the Issuer's principal markets may also negatively affect its business, results and financial
condition. For example, a sustained increase in the inflation rate may result in an increase in nominal market
interest rates. A failure to accurately anticipate higher inflation and factor it into the Issuer's product pricing
assumptions may result in mispricing of its products, which could materially and adversely impact its results.
On the other hand, negative interest rates may negatively impact the Issuer's net interest income, which may
have an adverse impact on its profitability.
A prolonged period of low interest rates, and in some situations negative interest rates, has resulted in, and may
continue to result in:
·
lower earnings over time on investments, as reinvestments will earn lower rates;
·
increased prepayment or redemption of mortgages and fixed maturity securities in the Issuer investment
portfolios, as well as increased prepayments of corporate loans. This as borrowers seek to borrow at
lower interest rates potentially combined with lower credit spreads. Consequently, the Issuer may be
required to reinvest the proceeds into assets at lower interest rates;
·
lower profitability as the result of a decrease in the spread between client rates earned on assets and
client rates paid on savings, current account and other liabilities;
·
higher costs for certain derivative instruments that may be used to hedge certain of the Issuer's product
risks;
·
lower profitability since the Issuer may not be able to fully track the decline in interest rates in its savings
rates;
·
lower profitability since the Issuer may not always be entitled to impose surcharges to customers to
compensate for the decline in interest rates;
·
lower profitability since the Issuer may have to pay a higher premium for the defined contribution
scheme in the Netherlands for which the premium paid is dependent on interest rate developments and
the Dutch Central Bank's ("DNB's") methodology for determining the ultimate forward rate;

7

·
lower interest rates may cause asset margins to decrease thereby lowering the Issuer's results. This may
for example be the consequence of increased competition for investments as result of the low rates,
thereby driving margins down; and/or
·
(depending on the position) a significant collateral posting requirement associated with the Issuer's
interest rate hedge programmes, which could materially and adversely affect liquidity and its
profitability.
The foregoing impacts have been and may be further amplified in a negative interest rate environment, since
the Issuer may not be able to earn interest on its assets (including reserves). In addition, ING has earned, and
may continue to, earn negative interest on certain of its assets (including cash balances, loans and bonds), while
still paying positive interest or no interest to others to hold its liabilities, resulting in an adverse impact on its
credit spread and lowering of its net interest income. Furthermore, in the event that a negative interest rate
environment results in ING's depositors being forced to pay interest to ING to hold cash deposits, some
depositors may choose to withdraw their deposits rather than pay interest to ING, which would have an adverse
effect on ING's reputation, business, results and financial condition. For example, in March 2020, the U.S.
Federal Reserve has cut the benchmark U.S. interest rate in response to the Covid-19 pandemic and related
impacts on the economy and financial markets. On 1 July 2021, ING announced in the Netherlands that it will
charge negative interest to customers on current and deposit accounts exceeding 100,000 (such negative
interest rate will only apply to the amount by which the current or deposit account exceeds 100,000). Such
declines in interest rates in the United States or other markets in which ING and its customers and counterparties
operate may have a significant adverse effect on ING's business and operations.
Alternatively, any period of rapidly increasing interest rates may result in:
·
a decrease in the demand for loans;
·
higher interest rates to be paid on customer deposits and on debt securities that the Issuer has issued or
may issue on the financial markets from time to time to finance its operations, which would increase its
interest expenses and reduce its results;
·
higher interest rates which can lead to lower investment prices and reduce the revaluation reserves,
thereby lowering IFRS equity and the capital ratios. Also the lower securities value leads to a loss of
liquidity generating capacity which needs to be compensated by attracting new liquidity generating
capacity which reduces the Issuer's results;
·
prepayment losses if prepayment rates are lower than expected or if interest rates increase too rapidly to
adjust the accompanying hedges; and/or
·
(depending on the position) a significant collateral posting requirement associated with the Issuer's
interest rate hedge programme.
The foregoing impacts grow in relevance following the U.S. Federal Reserve's plan to wind down its bond-
purchase stimulus programme and to set the stage for a series of interest rate increases beginning in spring of
2022.
The default of a major market participant could disrupt the markets and may have an adverse effect on the
Issuer's business, results and financial condition.
Within the financial services industry, the severe distress or default of any one institution (including sovereigns
and central counterparties (CCPs)) could lead to defaults by, or the severe distress of, other market participants.
While prudential regulation may reduce the probability of a default by a major financial institution, the actual
occurrence of such a default could have a material adverse impact on ING. Such distress of, or default by, a

8

major financial institution could disrupt markets or clearance and settlement systems and lead to a chain of
defaults by other financial institutions, since the commercial and financial soundness of many financial
institutions may be closely related as a result of credit, trading, clearing or other relationships. Also, the
perceived lack of creditworthiness of a sovereign or a major financial institution (or a default by any such entity)
may lead to market-wide liquidity problems and losses or defaults by the Issuer or by other institutions. This
risk is sometimes referred to as `systemic risk' and may adversely affect financial intermediaries, such as
clearing agencies, clearing houses, banks, securities firms and exchanges with whom the Issuer interacts on a
daily basis and financial instruments of sovereigns in which it invests. Systemic risk could impact ING directly,
by exposing it to material credit losses on transactions with defaulting counterparties or indirectly by
significantly reducing the available market liquidity on which ING and its lending customers depend to fund
their operations and/or leading to a write down of loans or securities held by ING. In addition, ING may also
be faced with additional open market risk for which hedging or mitigation strategies may not be available or
effective (either by hedges eliminated by defaulting counterparties, or reduced market liquidity). Systemic risk
could have a material adverse effect on ING's ability to raise new funding and on ING's business, results and
financial condition. In addition, such distress or failure could impact future product sales as a potential result
of reduced confidence in the financial services industry.
Continued risk of political instability and fiscal uncertainty in Europe and the United States, as well as
ongoing volatility in the financial markets and the economy generally have adversely affected, and may
continue to adversely affect, the Issuer's business, results and financial condition.
The Issuer's global business and results are materially affected by conditions in the global capital markets and
the economy generally. In Europe, there are continuing concerns over weaker economic conditions, levels of
unemployment in certain countries, the availability and cost of credit, as well as credit spreads. In addition,
geopolitical issues, including trade tensions between the US and China, increasing protectionism between key
countries, and issues with respect to the Middle East and North Korea may all contribute to adverse
developments in the global capital markets and the economy generally. In addition, Russia's recent invasion of
Ukraine and related international response measures may have a negative impact on regional and global
economic conditions, including as a result of disruptions in foreign currency markets and increased energy and
commodity prices. This could in turn have a spill-over effect on ING's entire Wholesale Banking portfolio, in
areas such as commodities financing, energy and utilities and energy-consuming clients.
Moreover, there is a risk that an adverse credit event at one or more European sovereign debtors (including a
credit rating downgrade or a default) could trigger a broader economic downturn in Europe and elsewhere. In
addition, the confluence of these and other factors has resulted in volatile foreign exchange markets.
International equity markets have also continued to experience heightened volatility and turmoil, with issuers,
including the Issuer, that have exposure to the real estate, mortgage, private equity and credit markets
particularly affected. These events, market upheavals and continuing risks, including high levels of volatility,
have had and may continue to have an adverse effect on the Issuer's results, in part because it has a large
investment portfolio.
There is also continued uncertainty over the long-term outlook for the tax, spending and borrowing policies of
the US, the future economic performance of the US within the global economy and any potential future
budgetary restrictions in the US, with a potential impact on a future sovereign credit ratings downgrade of the
US government, including the rating of US Treasury securities. A downgrade of US Treasury securities could
also impact the ratings and perceived creditworthiness of instruments issued, insured or guaranteed by
institutions, agencies or instrumentalities directly linked to the US government. US Treasury securities and
other US government-linked securities are key assets on the balance sheets of many financial institutions and
are widely used as collateral by financial institutions to meet their day-to-day cash flows in the short-term debt
market. The impact of any further downgrades to the sovereign credit rating of the US government or a default

9

by the US government on its debt obligations would create broader financial turmoil and uncertainty, which
would weigh heavily on the global financial system and could consequently result in a significant adverse
impact to the Issuer's business and operations.
In many cases, the markets for investments and instruments have been and remain illiquid, and issues relating
to counterparty credit ratings and other factors have exacerbated pricing and valuation uncertainties. Valuation
of such investments and instruments is a complex process involving the consideration of market transactions,
pricing models, management judgment and other factors, and is also impacted by external factors, such as
underlying mortgage default rates, interest rates, rating agency actions and property valuations. Historically
these factors have resulted in, among other things, valuation and impairment issues in connection with the
Issuer's exposures to European sovereign debt and other investments.
Any of these general developments in global financial and political conditions could negatively impact to the
Issuer's business, results and financial condition in future periods.
IBOR discontinuation of USD LIBOR may negatively affect the Issuer's business, results and financial
condition.
Changes to major interest rates benchmarks may negatively affect the Issuer's business, including the level of
net interest revenue. Financial markets have historically relied on Interbank Offered Rates ("IBORs")
benchmarks, such as the London Interbank Offered Rate ("LIBOR"), the Euro Over Night Index Average
("EONIA") and the Euro Interbank Offered Rate ("EURIBOR"). While some interest benchmarks have been
reformed and will continue to exist, such as EURIBOR, others such as EONIA and LIBOR have been or will
be replaced by alternative rates.
EONIA ceased to be published on 3 January 2022, and is succeeded by STR. All GBP, JPY, CHF and EUR
LIBOR settings ceased on 31 December 2021. ING has substantially completed the transition of contracts
referencing these benchmark rates and now offers the recommended alternative benchmark rates.
The most commonly used USD LIBOR tenors will continue to be published until 30 June 2023 to support
existing contracts. However, the use of USD LIBOR for new contracts is no longer allowed from January 2022,
with only limited exceptions.
Public authorities have recognised that many contracts do not contain reference to alternative rates, or reference
inappropriate alternatives, or cannot be renegotiated or amended prior to the cessation of the relevant
benchmark. In response, the European Commission has implemented legislation that gives the Commission the
power to replace critical benchmarks if their termination would significantly disrupt or otherwise affect the
functioning of the financial markets in the EU. The EU has used these powers to put in place statutory
replacement rates for EONIA and CHF LIBOR. The UK government has also granted additional powers to the
Financial Conduct Authority (FCA) to enable the temporary publication of a `synthetic` LIBOR using a
different methodology and inputs. The FCA has used these powers to ensure the most commonly used GBP and
JPY LIBOR settings continue to be available using a "synthetic" methodology for a limited time. The FCA has
not yet decided whether it will require the LIBOR benchmark administrator to publish synthetic USD LIBOR
after June 2023. On 6 April 2021, the State of New York passed legislation on benchmark replacement
addressing certain contracts, securities and instruments governed by New York which involve interest rates or
dividend rates determined by the use of USD LIBOR without "fallback" rate provisions or with inadequate
"fallback" rate provisions. A U.S. federal version of such legislation (passed by the U.S. House of
Representatives on 8 December 2021) remains under consideration in the U.S. Senate.
The discontinuation of USD LIBOR and related interest rate benchmarks could result in a number of risks for
the Group, its customers, and the financial services industry more widely. These risks include legal risks and
costs in relation to changes required to documentation for existing transactions. In addition to the heightened

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