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Ing Groep N.V. (ING)
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ING Groep (ING) Risk Factors

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Public companies are required to disclose risks that can affect the business and impact the stock. These disclosures are known as “Risk Factors”. Companies disclose these risks in their yearly (Form 10-K), quarterly earnings (Form 10-Q), or “foreign private issuer” reports (Form 20-F). Risk factors show the challenges a company faces. Investors can consider the worst-case scenarios before making an investment. TipRanks’ Risk Analysis categorizes risks based on proprietary classification algorithms and machine learning.

ING Groep disclosed 39 risk factors in its most recent earnings report. ING Groep reported the most risks in the “Finance & Corporate” category.

Risk Overview Q4, 2021

Risk Distribution
39Risks
28% Finance & Corporate
26% Macro & Political
23% Legal & Regulatory
10% Production
8% Tech & Innovation
5% Ability to Sell
Finance & Corporate - Financial and accounting risks. Risks related to the execution of corporate activity and strategy
This chart displays the stock's most recent risk distribution according to category. TipRanks has identified 6 major categories: Finance & corporate, legal & regulatory, macro & political, production, tech & innovation, and ability to sell.

Risk Change Over Time

2020
Q4
S&P500 Average
Sector Average
Risks removed
Risks added
Risks changed
ING Groep Risk Factors
New Risk (0)
Risk Changed (0)
Risk Removed (0)
No changes from previous report
The chart shows the number of risks a company has disclosed. You can compare this to the sector average or S&P 500 average.

The quarters shown in the chart are according to the calendar year (January to December). Businesses set their own financial calendar, known as a fiscal year. For example, Walmart ends their financial year at the end of January to accommodate the holiday season.

Risk Highlights Q4, 2021

Main Risk Category
Finance & Corporate
With 11 Risks
Finance & Corporate
With 11 Risks
Number of Disclosed Risks
39
+6
From last report
S&P 500 Average: 31
39
+6
From last report
S&P 500 Average: 31
Recent Changes
7Risks added
1Risks removed
5Risks changed
Since Dec 2021
7Risks added
1Risks removed
5Risks changed
Since Dec 2021
Number of Risk Changed
5
-2
From last report
S&P 500 Average: 3
5
-2
From last report
S&P 500 Average: 3
See the risk highlights of ING Groep in the last period.

Risk Word Cloud

The most common phrases about risk factors from the most recent report. Larger texts indicate more widely used phrases.

Risk Factors Full Breakdown - Total Risks 39

Finance & Corporate
Total Risks: 11/39 (28%)Below Sector Average
Share Price & Shareholder Rights2 | 5.1%
Share Price & Shareholder Rights - Risk 1
Changed
Holders of ING shares may experience dilution of their holdings and may be impacted by any share buyback programme.
ING’s AT1 Securities may, under certain circumstances, convert into equity securities. Such conversion woulddilute the ownership interests of existing holders of ING shares and such dilution could be substantial.Additionally, any conversion, or the anticipation of the possibility of a conversion, could depress the market priceof ING shares. Furthermore, we may undertake future equity offerings with or without subscription rights. In caseof equity offerings without subscription rights, holders of ING shares may suffer dilutions. In case of equityofferings with subscription rights, holders of ING shares in certain jurisdictions, however, may not be entitled toexercise such rights unless the rights and the related shares are registered or qualified for sale under the relevantlegislation or regulatory framework. Holders of ING shares in these jurisdictions may suffer dilution of theirshareholding should they not be permitted to, or otherwise chose not to, participate in future equity offeringswith subscription rights.Any share repurchases could affect the price of our ordinary shares, ADSs or other securities and increase tradingprice volatility. The existence of a share buyback programme could also cause the price of our ordinary shares,ADSs or other securities to be higher than it would be in the absence of such a share buyback programme, andcould potentially reduce the market liquidity of our ordinary shares, ADSs or other securities. There can be noassurance that any share buybacks will enhance shareholder value because the market price of our ordinaryshares or ADSs may decline below the levels at which we repurchase any ordinary shares or ADSs.In addition, ING cannot guarantee that any future share buyback programme will be fully consummated. Thetiming and amount of share repurchases pursuant to a share buyback programme will depend upon a number offactors, including market, business conditions, and the trading price of the our ordinary shares or ADSs. A sharebuyback programme may also be suspended or terminated at any time, and any such suspension or terminationcould negatively affect the trading price of, increase trading price volatility of or reduce the market liquidity ofour ordinary shares, ADSs or other securities. Additionally, a share buyback programme could diminish our cash reserves, which may impact our ability to finance future growth and to pursue possible future strategicopportunities
Share Price & Shareholder Rights - Risk 2
Added
Because we are incorporated under the laws of the Netherlands and many of the members ofour Supervisory and Executive Board and our officers reside outside of the United States, it maybe difficult to enforce judgments against ING or the members of our Supervisory and Executive Boards or our officers.
Most of our Supervisory Board members, our Executive Board members and some of the experts named in thisAnnual Report, as well as many of our officers are persons who are not residents of the United States, and mostof our and their assets are located outside the United States. As a result, investors may not be able to serveprocess on those persons within the United States or to enforce in the United States judgments obtained in UScourts against us or those persons based on the civil liability provisions of the US securities laws.Investors also may not be able to enforce judgments of US courts under the US federal securities laws in courtsoutside the United States, including the Netherlands. The United States and the Netherlands do not currentlyhave a treaty providing for the reciprocal recognition and enforcement of judgments (other than arbitrationawards) in civil and commercial matters. Therefore, a final judgment for the payment of money rendered by anyfederal or state court in the United States based on civil liability, whether or not predicated solely upon the U.S.federal securities laws, would not be enforceable in the Netherlands unless the underlying claim is re-litigatedbefore a Dutch court. However, under current practice, the courts of the Netherlands may be expected to rendera judgment in accordance with the judgment of the relevant U.S. court, provided that such judgment (i) is a finaljudgment and has been rendered by a court which has established its jurisdiction on the basis of internationallyaccepted grounds of jurisdictions, (ii) has not been rendered in violation of elementary principles of fair trial, (iii)is not contrary to the public policy of the Netherlands, and (iv) is not incompatible with (a) a prior judgment of aNetherlands court rendered in a dispute between the same parties, or (b) a prior judgment of a foreign courtrendered in a dispute between the same parties, concerning the same subject matter and based on the samecause of action, provided that such prior judgment is not capable of being recognized in the Netherlands. It isuncertain whether this practice extends to default judgments as well.Based on the foregoing, there can be no assurance that U.S. investors will be able to enforce against us ormembers of our board of directors, officers or certain experts named herein who are residents of the Netherlands or countries other than the United States any judgments obtained in U.S. courts in civil andcommercial matters, including judgments under the U.S. federal securities laws.In addition, there is doubt as to whether a Dutch court would impose civil liability on us, the members of ourboard of directors, our officers or certain experts named herein in an original action predicated solely upon theU.S. federal securities laws brought in a court of competent jurisdiction in the Netherlands against us or such members, officers or experts, respectively.
Accounting & Financial Operations2 | 5.1%
Accounting & Financial Operations - Risk 1
Risks relating to our use of quantitative models or assumptions to model client behaviour for thepurposes of our market calculations may adversely impact our reputation or results.
We use quantitative methods, systems or approaches that apply statistical, economic financial, or mathematicaltheories, techniques and assumptions to process input data into quantitative estimates. Errors in thedevelopment, implementation, use or interpretation of such models, or from incomplete or incorrect data, canlead to inaccurate, noncompliant or misinterpreted model outputs, which may adversely impact our reputationand results. In addition, we use assumptions in order to model client behaviour for the risk calculations in ourbanking books. Assumptions are used to determine the interest rate risk profile of savings and current accountsand to estimate the embedded option risk in the mortgage and investment portfolios. Assumptions based onpast client behaviour may not always be a reliable indicator of future behaviour. The realisation or use ofdifferent assumptions to determine client behaviour could have a material adverse effect on the calculated riskfigures and, ultimately, our future results or reputation. Furthermore, we may be subject to risks related tochanges in the laws and regulations governing the risk management practices of financial institutions. For furtherinformation, see “Risks related to the regulation and supervision of the Group – Changes in laws and/orregulations governing financial services or financial institutions or the application of such laws and/or regulationsmay increase our operating costs and limit our activities” above. As noted there, regulation of the industries inwhich we operates is becoming increasingly more extensive and complex, while also attracting supervisoryscrutiny. Compliance failures may lead to changes in the laws and regulations governing the risk management practices and materially increase our operating costs
Accounting & Financial Operations - Risk 2
Ratings are important to our business for a number of reasons, and a downgrade or a potentialdowngrade in our credit ratings could have an adverse impact on our results and net results.
Credit ratings represent the opinions of rating agencies regarding an entity’s ability to repay its indebtedness.Our credit ratings are important to our ability to raise capital and funding through the issuance of debt and to thecost of such financing. In the event of a downgrade, the cost of issuing debt will increase, having an adverseeffect on our net results. Certain institutional investors may also be obliged to withdraw their deposits from INGfollowing a downgrade, which could have an adverse effect on our liquidity. They can also have lower riskappetite for our debt notes, leading to lower purchases of (newly issued) debt notes. We have credit ratings fromS&P, Moody’s Investor Service and Fitch Ratings. Each of the rating agencies reviews its ratings and ratingmethodologies on a recurring basis and may decide on a downgrade at any time.As rating agencies continue to evaluate the financial services industry, it is possible that rating agencies willheighten the level of scrutiny that they apply to financial institutions, increase the frequency and scope of theircredit reviews, request additional information from the companies that they rate and potentially adjust upwardthe capital and other requirements employed in the rating agency models for maintenance of certain ratingslevels. It is possible that the outcome of any such review of us would have additional adverse ratingsconsequences, which could have a material adverse effect on our results and financial condition. We may need totake actions in response to changing standards or capital requirements set by any of the rating agencies, whichcould cause our business and operations to suffer. We cannot predict what additional actions rating agenciesmay take, or what actions we may take in response to the actions of rating agencies.Furthermore, ING Bank’s assets are risk-weighted. Downgrades of these assets could result in a higher risk-weighting, which may result in higher capital requirements. This may impact net earnings and the return oncapital, and may have an adverse impact on our competitive position.
Debt & Financing6 | 15.4%
Debt & Financing - Risk 1
The inability of counterparties to meet their financial obligations or our inability to fully enforceour rights against counterparties could have a material adverse effect on our results.
Third parties that have an payment obligations to ING, or obligations to return money, securities or other assets,may not pay or perform under their obligations. These parties include the issuers and guarantors (includingsovereigns) of securities we hold, borrowers under loans originated, reinsurers, customers, tradingcounterparties, securities lending and repurchase counterparties, counterparties under swaps, credit default andother derivative contracts, clearing agents, exchanges, clearing houses and other financial intermediaries.Defaults by one or more of these parties on their obligations to us due to bankruptcy, lack of liquidity, downturnsin the economy or real estate values, continuing low oil or other commodity prices, operational failure or otherfactors, or even rumours about potential defaults by one or more of these parties or regarding a severe distressof the financial services industry generally, could have a material adverse effect on our results, financial conditionand liquidity. Given the high level of interdependence between financial institutions, we are and will continue tobe subject to the risk of deterioration of the commercial and financial soundness, or perceived soundness, ofsovereigns and other financial services institutions. This is particularly relevant to our franchise as an importantand large counterparty in equity, fixed income and foreign exchange markets, including related derivatives.We routinely execute a high volume of transactions, such as unsecured debt instruments, derivative transactionsand equity investments with counterparties and customers in the financial services industry, including brokersand dealers, commercial and investment banks, mutual and hedge funds, insurance companies, institutionalclients, futures clearing merchants, swap dealers, and other institutions, resulting in large periodic settlementamounts, which may result in us having significant credit exposure to one or more of such counterparties orcustomers. As a result, we could face concentration risk with respect to liabilities or amounts we expect to collect from specific counterparties and customers. We are exposed to increased counterparty risk as a result of recentfinancial institution failures and weakness and will continue to be exposed to the risk of loss if counterpartyfinancial institutions fail or are otherwise unable to meet their obligations. As a result of the Russian invasion ofUkraine and related international response measures, including sanctions and capital controls, we may beexposed to increased risk of default of counterparties located in Russia and Ukraine, counterparties of which theultimate parent is located in Russia or may be considered effectively controlled or influenced through Russianinvolvement, and other counterparties in sectors affected by the response measures. Also liquidity or currencycontrols enforced by the Russian Central Bank may impact Russian companies ability to pay. In addition, we havecounterparty exposure to Russian entities in connection with foreign exchange derivatives for future receipt offoreign currencies against RUB. Of our total EUR 600 billion loan book, the total Russia exposure is around EUR6.7 billion on 28 February 2022 and EUR 500 million with clients in Ukraine. A default by, or even concerns aboutthe creditworthiness of, one or more of these counterparties or customers or other financial services institutionscould therefore have an adverse effect on our results or liquidity.With respect to secured transactions, our credit risk may be exacerbated when the collateral held by us cannotbe or is liquidated at prices not sufficient to recover the full amount of the loan or derivative exposure due to us.We also have exposure to a number of financial institutions in the form of unsecured debt instruments,derivative transactions and equity investments. For example, we hold certain hybrid regulatory capitalinstruments issued by financial institutions which permit the issuer to cancel coupon payments on theoccurrence of certain events or at their option. The EC has indicated that, in certain circumstances, it may requirethese financial institutions to cancel payment. If this were to happen, we expect that such instruments mayexperience ratings downgrades and/or a drop in value and we may have to treat them as impaired, which couldresult in significant losses. There is no assurance that losses on, or impairments to the carrying value of, theseassets would not materially and adversely affect our business, results or financial condition.In addition, we are subject to the risk that our rights against third parties may not be enforceable in allcircumstances. The deterioration or perceived deterioration in the credit quality of third parties whose securitiesor obligations we hold could result in losses and/ or adversely affect our ability to rehypothecate or otherwiseuse those securities or obligations for liquidity purposes. A significant downgrade in the credit ratings of ourcounterparties could also have a negative impact on our income and risk weighting, leading to increased capitalrequirements. While in many cases we are permitted to require additional collateral from counterparties thatexperience financial difficulty, disputes may arise as to the amount of collateral we are entitled to receive andthe value of pledged assets. Also in this case, our credit risk may also be exacerbated when the collateral we hold cannot be liquidated at prices sufficient to recover the full amount of the loan or derivative exposure due to us,which is most likely to occur during periods of illiquidity and depressed asset valuations, such as thoseexperienced during the financial crisis of 2008. The termination of contracts and the foreclosure on collateralmay subject us to claims. Bankruptcies, downgrades and disputes with counterparties as to the valuation ofcollateral tend to increase in times of market stress and illiquidity. Any of these developments or losses couldmaterially and adversely affect our business, results, financial condition, and/or prospects
Debt & Financing - Risk 2
We may incur losses due to failures of banks falling under the scope of state compensation schemes
While prudential regulation is intended to minimize the risk of bank failures, in the event such a failure occurs,given our size, we may incur significant compensation payments to be made under the Dutch Deposit GuaranteeScheme (DGS), which we may be unable to recover from the bankrupt estate, and therefore the consequences ofany future failure of such a bank could be significant to ING. Such costs and the associated costs to be borne byus may have a material adverse effect on our results and financial condition. On the basis of the EU Directive ondeposit guarantee schemes, ING pays quarterly risk-weighted contributions into a DGS-fund. The DGS-fund is togrow to a target size of 0.8% of all deposits guaranteed under the DGS, which is expected to be reached in July2024. In case of failure of a Dutch bank, depositor compensation is paid from the DGS-fund. If the availablefinancial means of the fund are insufficient, Dutch banks, including ING, may be required pay to extraordinary ex-post contributions not exceeding 0.5% of their covered deposits per calendar year. In exceptional circumstancesand with the consent of the competent authority, higher contributions may be required. However, extraordinaryex-post contributions may be temporarily deferred if, and for so long as, they would jeopardise the solvency orliquidity of a bank. Depending on the size of the failed bank, the available financial means in the fund, and therequired additional financial means, the impact of the extraordinary ex-post contributions on ING may bematerial.Since 2015, the EU has been discussing the introduction of a pan-European deposit guarantee scheme (‘EDIS’),(partly) replacing or complementing national compensation schemes in two or three phases. Proposals containelements of (re)insurance, mutual lending and mutualisation of funds. The new model is intended to be ‘overallcost-neutral’. Discussions have continued in 2020, but it remains uncertain when EDIS will be introduced and, ifintroduced, what impact EDIS would have on ING’s business and operations.In February 2021, the European Commission issued a public consultation on the review of the bank crisismanagement and deposit insurance (CMDI) framework, with a focus on three EU legislative texts: the BankRecovery and Resolution Directive (BRRD), the Single Resolution Mechanism Regulation (SRMR), and the DepositGuarantee Schemes Directive (DGSD). The anticipated revision of the CMDI framework is part of the debate onthe completion of the Banking Union and in particular its third and missing pillar EDIS. The consultation periodran until May 2021. It is uncertain when the next steps towards revision of the CMDI framework, including EDIS, can be expected.
Debt & Financing - Risk 3
Interest rate volatility and other interest rate changes may adversely affect our business, results and financial condition.
Changes in prevailing interest rates may negatively affect our business, including the level of net interest revenuewe earn, and the levels of deposits and the demand for loans. A sustained increase in the inflation rate in ourprincipal markets may also negatively affect our business, results and financial condition. For example, asustained increase in the inflation rate may result in an increase in nominal market interest rates. A failure toaccurately anticipate higher inflation and factor it into our product pricing assumptions may result in mispricingof our products, which could materially and adversely impact our results. On the other hand, negative interestrates may negatively impact our net interest income, which may have an adverse impact on our profitability.A prolonged period of low interest rates, and in some situations negative interest rates, has resulted in, and maycontinue 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 our investmentportfolios, as well as increased prepayments of corporate loans. This as borrowers seek to borrow atlower interest rates potentially combined with lower credit spreads. Consequently, we may be requiredto 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 andclient rates paid on savings, current account and other liabilities;?higher costs for certain derivative instruments that may be used to hedge certain of our product risks;?lower profitability since we may not be able to fully track the decline in interest rates in our savingsrates;?lower profitability since we may not always be entitled to impose surcharges to customers tocompensate for the decline in interest rates;?lower profitability since we may have to pay a higher premium for the defined contribution scheme inthe Netherlands for which the premium paid is dependent on interest rate developments and the DutchCentral Bank’s (“DNB’s”) methodology for determining the ultimate forward rate;?lower interest rates may cause asset margins to decrease thereby lowering our results. This may forexample 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 our interest ratehedge programs, which could materially and adversely affect liquidity and our profitability. The foregoing impacts have been and may be further amplified in a negative interest rate environment, since wemay not be able to earn interest on our assets (including reserves). In addition, we have, and may continue to,earn negative interest on certain of our assets (including cash balances, loans and bonds), while still payingpositive interest or no interest to others to hold our liabilities, resulting in an adverse impact on our credit spreadand lowering of our net interest income. Furthermore, in the event that a negative interest rate environmentresults in ING’s depositors being forced to pay interest to ING to hold cash deposits, some depositors may chooseto withdraw their deposits rather than pay interest to ING, which would have an adverse effect on ourreputation, business, results and financial condition. For example, in March 2020, the U.S. Federal Reserve hascut the benchmark U.S. interest rate in response to the Covid-19 pandemic and related impacts on the economyand financial markets. On 1 July 2021, ING announced in the Netherlands that it will charge negative interest tocustomers on current and deposit accounts exceeding €100,000 (such negative interest rate will only apply to theamount by which the current or deposit account exceeds €100,000 ). Such declines in interest rates in the UnitedStates or other markets in which ING and its customers and counterparties operate may have a significantadverse effect on our 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 we have issued or mayissue on the financial markets from time to time to finance our operations, which would increase ourinterest expenses and reduce our results;?higher interest rates which can lead to lower investments prices and reduce the revaluation reserves,thereby lowering IFRS equity and the capital ratios. Also the lower securities value leads to a loss ofliquidity generating capacity which needs to be compensated by attracting new liquidity generatingcapacity which reduces our results;?prepayment losses if prepayment rates are lower than expected or if interest rates increase too rapidlyto adjust the accompanying hedges; and/or?(depending on the position) a significant collateral posting requirement associated with our interest ratehedge program.The foregoing impacts grow in relevance following the U.S. Federal Reserve’s plan to wind down its bond-purchase stimulus program and to set the stage for a series of interest rate increases beginning in spring of 2022
Debt & Financing - Risk 4
As a holding company, ING Groep N.V. is dependent for liquidity on payments from itssubsidiaries, many of which are subject to regulatory and other restrictions on their ability to transact with affiliates
ING Groep N.V. is a holding company and, therefore, depends on dividends, distributions and other paymentsfrom its subsidiaries to fund dividend payments to its shareholders and to fund all payments on its obligations,including debt service obligations. ING Groep N.V.’s ability to obtain funds to meet its obligations depends on legal and regulatory restrictionsapplicable to ING Groep N.V.’s subsidiaries. Many of ING Groep N.V.’s direct and indirect subsidiaries, includingcertain subsidiaries of ING Bank N.V., may be subject to laws that restrict dividend payments, as well asrequirements with respect to capital and liquidity levels. For example, certain local governments and regulatorshave taken steps and may take further steps to “ring fence” or impose minimum internal total loss-absorbingcapacity on the local affiliates of a foreign financial institution in order to protect clients and creditors of suchaffiliates in the event of financial difficulties involving such affiliates or the broader banking group. Increasedlocal regulation and supervision have therefore limited and may in the future further limit the ability to movecapital and liquidity among affiliated entities and between ING Groep N.V. and its direct and indirect subsidiaries,limit the flexibility to structure intercompany and external activities of ING as otherwise deemed mostoperationally efficient, and increase in the overall level of capital and liquidity required by ING on a consolidatedbasis.Lower earnings of a local entity may also reduce the ability of such local entity to make dividends anddistributions to ING Groep N.V. Other restrictions, such as restrictions on payments from subsidiaries orlimitations on the use of funds in client accounts, may also apply to distributions to ING Groep N.V. from itssubsidiaries. ING Groep N.V. has also in the past guaranteed and may in the future continue to guarantee the paymentobligations of some of its subsidiaries, including ING Bank N.V. Any such guarantees may require ING Groep N.V.to provide substantial funds or assets to its subsidiaries or the creditors or counterparties of these subsidiaries ata time when the guaranteed subsidiary is in need of liquidity to fund its own obligations.Finally, ING Groep N.V., as the resolution entity of ING, has an obligation to remove impediments to resolutionand to improve resolvability. Regulatory authorities have required and may continue to require ING to increase capital or liquidity levels at the level of the resolution entity or at particular subsidiaries. This may result in,among other things, the issuance of additional long-term debt issuance at the level of ING Groep N.V. orparticular subsidiaries
Debt & Financing - Risk 5
Changed
Discontinuation of USD LIBOR may negatively affect our business, results and financial condition
Changes to major interest rates benchmarks may negatively affect our business, including the level of net interestrevenue. Financial markets have historically relied on Interbank Offered Rates (‘IBORs’) benchmarks, such as theLondon Interbank Offered Rate (‘LIBOR’), the Euro Over Night Index Average (‘EONIA’) and the Euro InterbankOffered Rate (‘EURIBOR’). While some interest benchmarks have been reformed and will continue to exist, suchas EURIBOR, others such as EONIA and LIBOR have been or will be replaced by alternative rates. EONIA ceased tobe published on 3 January 2022, and is succeeded by €STR. All GBP, JPY, CHF and EUR LIBOR settings ceased on31 December 2021. ING has substantially completed the transition of contracts referencing these benchmarkrates 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 existingcontracts. However, the use of USD LIBOR for new contracts is no longer allowed from January 2022, with onlylimited exceptions.Public authorities have recognised that many contracts do not contain reference to alternative rates, orreference inappropriate alternatives, or cannot be renegotiated or amended prior to the cessation of therelevant benchmark. In response, the European Commission has implemented legislation that gives theCommission the power to replace critical benchmarks if their termination would significantly disrupt or otherwiseaffect the functioning of the financial markets in the EU. The EU has used these powers to put in place statutoryreplacement rates for EONIA and CHF LIBOR. The UK government has also granted additional powers to theFinancial Conduct Authority (FCA) to enable the temporary publication of a ‘synthetic‘ LIBOR using a differentmethodology and inputs. The FCA has used these powers to ensure the most commonly used GBP and JPYLIBOR settings continue to be available using a “synthetic” methodology for a limited time. The FCA has not yetdecided whether it will require the LIBOR benchmark administrator to publish synthetic USD LIBOR after June2023. 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 ratesdetermined by the use of USD LIBOR without “fallback” rate provisions or with inadequate “fallback” rateprovisions. A U.S. federal version of such legislation (passed by the U.S. House of Representatives on 8 December2021) 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 theGroup, its customers, and the financial services industry more widely. These risks include legal risks and costs inrelation to changes required to documentation for existing transactions. In addition to the heightened conductand operational risks, the process of adopting new reference rates may expose the Group to an increased level offinancial risk, such as potential earnings volatility resulting from contract modifications and changes in hedgeaccounting relationships. It is not possible to determine the full impact of the USD LIBOR transition on the Group. However, the experiencegained and solutions put in place for the other LIBOR rates, together with our investment in and ability to offer awide range of products using alternative rates, should help to limit any material adverse effect on our business,results and financial condition
Debt & Financing - Risk 6
We are subject to several other bank recovery and resolution regimes that include statutorywrite down and conversion as well as other powers, which remains subject to significant uncertainties as to scope and impact on us.
We are subject to several recovery and resolution regimes, including the Single Resolution Mechanism (‘SRM’),the ‘Bank Recovery and Resolution Directive’ (‘BRRD’) as implemented in national legislation, and the Dutch‘Intervention Act’ (Wet bijzondere maatregelen financiële ondernemingen, as implemented in the DutchFinancial Supervision Act). The SRM applies to banks that are supervised by the ECB under the SSM, with the aimof ensuring an orderly resolution of failing banks at minimum costs for taxpayers and the real economy. TheBRRD establishes a common framework for the recovery and resolution for banks within the European Union,with the aim of providing supervisory authorities and resolution authorities with common tools and powers toaddress banking crises pre-emptively in order to safeguard financial stability and minimise taxpayers’ exposure tolosses. In addition, the Intervention Act confers wide-ranging powers to the Dutch Minister of Finance, including,among other things, in relation to shares and other securities issued by us or with our cooperation or otherclaims on us (including, without limitation, expropriation thereof) if there is a serious and immediate threat tothe stability of the financial system. Any application of statutory write-down and conversion or other powerswould not be expected to constitute an event of default under our securities entitling holders to seek repayment.If any of these powers were to be exercised in respect of ING, there could be a material adverse effect on bothING and on holders of ING securities, including through a material adverse effect on credit ratings and/or the price of our securities. Investors in our securities may lose their investment if resolution measures are takenunder current or future regimes.For further discussion of the impact of bank recovery and resolution regimes on ING, see “Item 4. Information onthe Company—Regulation and Supervision—Regulatory Developments—Bank Recovery and Resolution Directive.”
Corporate Activity and Growth1 | 2.6%
Corporate Activity and Growth - Risk 1
Added
ING may be unable to meet internal or external aims or expectations with respect to ESG-related matters.
Environmental, Social and Governance (ESG) is an area of significant and increased focus for governments andregulators, investors, ING’s customers and employees, and other stakeholders or third parties (e.g., non-governmental organizations or NGOs). As a result, an increasing number of laws, regulations and legislativeactions have been introduced to address climate change, sustainability and other ESG-related matters, includingin relation to the financial sector’s operations and strategy. Such recent regulations include the EU SustainableFinance Disclosure Regulation (SFDR), EU Taxonomy Regulation and EU Green Bond Standards, which broadlyfocus on disclosure obligations, standardized definitions and classification frameworks for environmentallysustainable activities. These laws, regulations and legislative frameworks may directly and indirectly impact thebusiness environment in which ING operates and may expose ING to significant risks.National or international regulatory actions or developments may also result in financial institutions comingunder increased pressure from internal and external stakeholders regarding the management and disclosure oftheir ESG risks and related lending and investment activities. ING may from time to time disclose ESG-relatedinitiatives or aims in connection with the conduct of its business and operations. However, there is no guaranteethat ING will be able to implement such initiatives or meet such aims within anticipated timeframes, or at all. INGmay fail to fulfil internal or external ESG-related initiatives, aims or expectations, or may be perceived to fail todo so, or may fail to adequately or accurately report performance or developments with respect to suchinitiatives, aims or expectations. ING could therefore be criticized or held responsible for the scope of itsinitiatives or goals regarding such matters. In addition, ING might face requests for specific strategies, plans orcommitments to address ESG-related matters, which may or may not be viewed as satisfactory to the relevant internal and external stakeholders (including NGOs). Any of these factors may have an adverse impact on ING’sreputation and brand value, or on ING’s business, financial condition and operating results.
Macro & Political
Total Risks: 10/39 (26%)Above Sector Average
Economy & Political Environment4 | 10.3%
Economy & Political Environment - Risk 1
Added
Continued risk of political instability and fiscal uncertainty in Europe and the United States, aswell as ongoing volatility in the financial markets and the economy generally have adverselyaffected, and may continue to adversely affect, our business, results and financial condition
Our global business and results are materially affected by conditions in the global capital markets and theeconomy generally. In Europe, there are continuing concerns over weaker economic conditions, levels ofunemployment 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 adversedevelopments in the global capital markets and the economy generally. In addition, Russia’s recent invasion ofUkraine and related international response measures may have a negative impact on regional and globaleconomic conditions, including as a result of disruptions in foreign currency markets and increased energy andcommodity prices. This could in turn have a spill-over effect on our entire wholesale banking portfolio, in areassuch 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 acredit rating downgrade or a default) could trigger a broader economic downturn in Europe and elsewhere. Inaddition, 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 ourselves, that have exposure to the real estate, mortgage, private equity and credit marketsparticularly affected. These events, market upheavals and continuing risks, including high levels of volatility, havehad and may continue to have an adverse effect on our results, in part because we have a large investmentportfolio.There is also continued uncertainty over the long-term outlook for the tax, spending and borrowing policies ofthe US, the future economic performance of the US within the global economy and any potential futurebudgetary restrictions in the US, with a potential impact on a future sovereign credit ratings downgrade of the USgovernment, including the rating of US Treasury securities. A downgrade of US Treasury securities could alsoimpact 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 USgovernment-linked securities are key assets on the balance sheets of many financial institutions and are widelyused as collateral by financial institutions to meet their day-to-day cash flows in the short-term debt market. Theimpact of any further downgrades to the sovereign credit rating of the US government or a default by the USgovernment on its debt obligations would create broader financial turmoil and uncertainty, which would weighheavily on the global financial system and could consequently result in a significant adverse impact to theGroup’s business and operations.In many cases, the markets for investments and instruments have been and remain illiquid, and issues relating tocounterparty credit ratings and other factors have exacerbated pricing and valuation uncertainties. Valuation ofsuch 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. Historicallythese factors have resulted in, among other things, valuation and impairment issues in connection with ourexposures to European sovereign debt and other investments.Any of these general developments in global financial and political conditions could negatively impact to our business, results and financial condition in future periods.
Economy & Political Environment - Risk 2
The regulatory consequences of the United Kingdom’s withdrawal from the European Union mayhave adverse effects on our business, results and financial condition
On 24 December 2020, the United Kingdom and the EU agreed to the EU-UK Trade and Cooperation Agreement(the “TCA”) in connection with the departure of the UK from the EU (commonly referred to as ‘Brexit’). However,the financial services provisions of the TCA are very limited and , as a result, UK-based financial services providerslost EU passporting rights as of 1 January 2021 and EU-UK financial services are now subject to unilateralequivalence decisions. EU and UK regulators have, however, taken certain measures to address overall financialstability risks, such as the temporary extension by the EU of equivalence recognition to UK-based centralcounterparties (UK CCPs) through to 30 June 2022. In November 2021 the European Commissioner for financialservices announced that the 30 June 2022 extension date will be further extended in early 2022, although theduration of the extension has not yet been specified. There is, however, no guarantee that such equivalencedecisions will be issued by the EU or the UK in the future, or that any further extensions or renewals of temporary equivalence decisions or similar transitional arrangements will be made by the EU or the UK in thefuture. The absence of such equivalence decisions for financial services could have a negative impact on ING’sactivities, with the absence of future UK CCPs recognition expected to increase costs for both ING and itsfinancial markets customers. In addition, Brexit has required and will require other changes to ING’s business andoperations, including requiring ING to obtain a third country branch banking license in the UK, which was grantedin November 2021. ING is also progressing the move of certain financial markets activities from London toAmsterdam in light of the ECB’s supervisory expectations on booking models as a result of Brexit. The regulatoryimpact of Brexit continues to present material risks and uncertainties, particularly as to how regulations maydiverge between the EU and the UK, which could materially increase ING’s compliance costs and have a materialadverse effect on ING’s business, results and financial condition.
Economy & Political Environment - Risk 3
Our 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 whichwe conduct business, as well as by changes in customer behaviour in these regions, and anadverse change in any one region could have an impact on our business, results and financialcondition.
Because ING is a multinational banking and financial services corporation, with a global presence and servingaround 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 financialmarkets or in the particular geographic areas in which we operate. In Retail Banking, our products includesavings, payments, investments, loans and mortgages in most of our Retail Banking markets. In WholesaleBanking, we provide 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/orcountries or regions in which we operate, have in the past had and may in the future have a material adverseimpact on our business, results and financial condition, including as a result of the potential consequences listedbelow.Factors such as interest rates, securities prices, credit spreads, liquidity spreads, exchange rates, consumerspending, changes in customer behaviour, climate change, business investment, real estate values and privateequity 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 asCovid-19, as described in greater detail below under the heading “– ING’s business, results and financialcondition have been, and likely will continue to be adversely affected by the Covid-19 pandemic”) or otherwidespread health emergencies all impact the business and economic environment and, ultimately, our solvency,liquidity and the amount and profitability of business we conduct in a specific geographic region. Certain of theserisks are often experienced globally as well as in specific geographic regions and are described in greater detailbelow under the headings “–Interest rate volatility and other interest rate changes may adversely affect ourbusiness, results and financial condition”, “–Inflation and deflation may negatively affect our business, resultsand financial condition”, “–Market conditions, including those observed over the past few years and theapplication of IFRS 9 may increase the risk of loans being impaired and have a negative effect on our results and inancial condition” and “–Continued risk of political instability and fiscal uncertainty in Europe and the UnitedStates, as well as ongoing volatility in the financial markets and the economy generally have adversely affected,and may continue to adversely affect, our business, results and financial condition”. All of these are factors inlocal and regional economies as well as in the global economy, and we may be affected by changes in any one ofthese factors in any one country or region, and more if more of these factors occur simultaneously and/or inmultiple countries or regions or on a global scale.In case one or more of the factors mentioned above adversely affects the profitability of our business, this mightalso result, among other things, in the following:?inadequate reserves or provisions, in relation to which losses could ultimately be realised through profitand 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 our net result andequity; and/or?movements in risk weighted assets for the determination of required capital.In particular, we are exposed to financial, economic, market and political conditions in the Benelux countries andGermany, from which we derive a significant portion of our revenues in both Retail Banking and WholesaleBanking, and which could present risks of economic downturn. Though less material, we also derive substantialrevenues in the following geographic regions: Turkey, Eastern Europe (primarily Poland among others), SouthernEurope (primarily Spain among others), East Asia (primarily Singapore among others) and Australia. In aneconomic downturn affecting some or all of these jurisdictions, we expect that higher unemployment, lowerfamily income, lower corporate earnings, higher corporate and private debt defaults, lower business investmentsand lower consumer spending would adversely affect the demand for banking products, and that ING may needto increase its reserves and provisions, each of which may result in overall lower earnings. The impact of theCovid-19 pandemic, as an example of an economic downturn, as well as the substantial monetary andgovernment measures, are still materialising and expected to continue to affect our business. For moreinformation, refer to the risk factor described under heading “–ING’s business, results and financial conditionhave been, and likely will continue to be adversely affected by the Covid-19 pandemic”. We also have wholesalebanking activities in both Russia and Ukraine, as well as investments in Russia, some of which are denominated inlocal currency. The impact on our business in Russia and Ukraine, as well as the potential regional and globaleconomic 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 our broader business,including spill-over risk to the entire wholesale banking portfolio (e.g. commodities financing, energy and utilitiesand energy-consuming clients), remain uncertain. Securities prices, real estate values and private equityvaluations may also be adversely impacted, and any such losses would be realised through profit and loss andshareholders’ equity. We also offer a number of financial products that expose us to risks associated withfluctuations 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 36 ‘Information ongeographic areas’ to the consolidated financial statements.
Economy & Political Environment - Risk 4
Changed
Inflation and deflation may negatively affect our business, results and financial condition
A sustained increase in the inflation rate in our principal markets could have multiple impacts on us and maynegatively affect our business, results and financial condition. For example, a sustained increase in the inflationrate may result in an increase in market interest rates, which may:?decrease the estimated fair value of certain fixed income securities that we hold in our investmentportfolios, resulting in:?reduced levels of unrealised capital gains available to us, which could negatively impact oursolvency position and net income, and/or?a decrease in collateral values,?result in increased withdrawal of certain savings products, particularly those with fixed rates belowmarket rates,?require us, as an issuer of securities, to pay higher interest rates on debt securities that we issue in thefinancial markets from time to time to finance our operations, which would increase our interestexpenses and reduce our results,?result in further customer defaults as interest rate rises flow through into payment stress for lowercredit quality customers.A significant and sustained increase in inflation has historically also been associated with decreased prices forequity securities and sluggish performance of equity markets generally. A sustained decline in equity marketsmay:?result in impairment charges to equity securities that we hold in our investment portfolios and reducedlevels of unrealised capital gains available to us which would reduce our net income, and?lower the value of our equity investments impacting our capital position.In addition, a failure to accurately anticipate higher inflation and factor it into our product pricing may result in asystemic mispricing of our products, which would negatively impact our results.On the other hand, deflation could be experienced in our principal markets adversely affecting our financialperformance. Deflation may erode collateral values and diminish the quality of loans and cause a decrease inborrowing levels, which would negatively affect our business and results.
Natural and Human Disruptions3 | 7.7%
Natural and Human Disruptions - Risk 1
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 localgovernmental authorities aimed at preventing the further spread of the disease (such as bans on public eventswith 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) havedisrupted the normal flow of business operations in those countries and regions where we and our customersand counterparties operate (such as, among others, Benelux, Germany, France, Italy, Spain, the U.K. and theU.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 hasresulted in volatility and uncertainty across the global economy and financial markets. Please also refer to theinterdependent risk factor ‘–ING’s revenues and earnings are affected by the volatility and strength of theeconomic, business, liquidity, funding and capital markets environments of the various geographic regions inwhich it conducts business, and an adverse change in any one region could have an impact on its business, resultsand financial condition’ for a further description of how ING’s business, results and financial condition may bematerially 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 banksaround the world have also introduced measures aimed at mitigating the economic consequences of thepandemic and related response measures, such as guarantee schemes, compensation schemes and cuttinginterest rates. For example, the Dutch government has implemented economic measures aimed at protectingjobs, 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 anyadditional measures, including any payment holidays with respect to mortgages or other loans, have had andmay continue to have a significant impact on our customers and other counterparties.Governments, regulators and central banks (including the ECB), have also announced that they are taking orconsidering measures seeking to safeguard the stability of the financial sector, to prevent lending to the businesssector from being jeopardised and to ensure the payment system continues to function properly. The ECB allowsbanks to operate below the level of capital required by the Pillar 2 Guidance, capital conservation buffer and theliquidity coverage ratio. The ECB has communicated its commitment to extend this permission until at least theend of 2022. In March 2020, several countries also released or reduced countercyclical buffers (CCyB), with someof these countries subsequently announcing increases in CCyB in the second half of 2022. The ECB’srecommendation to the banks that it supervises to limit shareholder remuneration through dividends or sharebuy-backs expired on 30 September 2021. However, it is not certain whether these or future Covid-19 reliefmeasures will be extended or maintained for a sufficient period of time, or whether such measures will besuccessful in mitigating the economic consequences of the pandemic and related response measures. If thepandemic is prolonged or the actions are unsuccessful, additional actions by governments and central banks mayfollow and the adverse impact on the global economy will deepen, and our business, results and financialcondition may be materially adversely affected. In 2020, the Covid-19 pandemic affected all of our businesses, including lower or negative interest rates, lower oilprices and credit deterioration of loans to ING’s customers. These effects have also resulted in an increase in theallowance for credit losses and impairments on non-financial assets, and reduced net interest income due tolower interest rates. While these effects were partly offset by resilient fee and commission income in 2020, thislevel of activity may not persist in future periods. While vaccination rates continued to increase and Covid-19 related restrictions were lifted in some jurisdictionsin the third quarter of 2021, the end of the 2021 was again marked by an increasing number of Covid-19infections. 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 mayresult in further negative impact on our business, results and financial condition. In 2021, ING also took certain measures to support customers impacted by the Covid-19 pandemic, includingpayment holidays, offering credit facilities to business clients under government guarantee schemes andproviding liquidity under credit facilities to large corporate clients. As of 31 December 2021, in line with theEuropean Banking Association (EBA) moratoria guidelines, approximately 137,000 customers had been grantedpayment holidays (down from 148,000 as of 30 September 2021 due to reimbursements and prepayments). Thetotal exposure of loans for these customers for which a payment holiday has been granted amounts to €15.3billion, of which 57% were for customers located in the Netherlands and Belgium. As of 31 December 2021, theoutstanding 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 existingStage 3 files reflecting uncertainty in recovery scenarios and valuations in certain asset classes and also reflectinga potential impact of higher inflation and interest rates on customers’ ability to pay and the potential impact ofmarket uncertainty on the recovery value of certain asset classes. In 2021, ING recorded €516 million of netadditions 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 pandemicremained. Should these global economic conditions be prolonged or worsen, or should the pandemic lead toadditional market disruptions, we may experience more client defaults and further additions to loan lossprovisions. In these circumstances, we may also experience reduced client activity and demand for its productsand services, increased utilization of lending commitments and higher credit and valuation adjustments onfinancial assets. In addition, persistently low interest rates for a longer period, as well as a potential furtherdecline in interest rates might result in further decreases in net interest income. These factors and otherconsequences of the Covid-19 pandemic may materially adversely affect our business, results and financialcondition.Our capital and liquidity position may also be adversely impacted by the Covid-19 pandemic and related responsemeasures, including as a result of changes in future levels of savings and deposits from customers, changes inasset quality, and the effects of government or regulatory responses to the pandemic, and may require changesto our funding structure, impact our ability to comply with regulatory capital requirements and adversely affectour cost of capital and credit rating. Any of the foregoing developments may have a material adverse impact onour business, results and financial condition.As of December 31, 2021, most of our staff continue to work from home, with employees in certain jurisdictionsbeginning to return to ING’s offices in a controlled manner, taking into account local circumstances and anyapplicable government measures (including with respect to social distancing where applicable). Due to theuncertainties relating to the future development of the Covid-19 pandemic, it is not certain when our employeesmay 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 ableto operate as effectively and efficiently as they did in the office, this may adversely affect our business, resultsand financial condition. In addition, a situation in which most or some of our employees continue working from home may raiseoperational risks, including with respect to information security, data protection, availability of key systems andinfrastructure integrity. There is also a risk that we will not be effective in implementing regulatory or strategicchange programs in the current environment. The Covid-19 pandemic has led to new banking behaviour fromcustomers. There has been an increase in the digital behaviour of our customers leading to reduced traffic inbranches. Over 95% of our customers now interact with us via digital channels only. Criminals are also takingadvantage of the Covid-19 pandemic to carry out financial fraud and exploitation scams, with examples includingadvertising and trafficking in counterfeit medicines, offering fraudulent investment opportunities, fundraising forfake charities and engaging in phishing schemes that prey on virus-related fears. National authorities andinternational bodies (including the Financial Action Task Force) warn citizens and businesses against impostor,investment and product scams. Although we have organized a Covid-19 taskforce to identify and analyse newbehavioural 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 tomaterialize that may adversely affect our 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 certaincountries which may result in increased volatility and widening credit spreads, remain uncertain. Therefore, it isdifficult to predict the extent to which our business, results and financial condition, as well as our ability to accesscapital and liquidity on financial terms acceptable for us, may be materially adversely affected.
Natural and Human Disruptions - Risk 2
Added
ING’s business and operations are exposed to transition risks related to climate change.
he transition to a low carbon or net zero economy may give rise to risks and uncertainties associated withclimate change-related laws, regulations and oversight, changing or new technologies, and shifting customersentiment. For instance, ING may be required to change its lending portfolio to comply with new climate change-related regulations. As a result, it might be unable to lend to certain prospective customers, or might even lead tothe termination of certain existing relationships with certain customers. This could result in claims or legalchallenges from such customers against ING. This transition may also adversely impact the business andoperations of ING’s customers and other counterparties. If ING fails to adequately factor in such risks in itslending or other business decisions, ING could be exposed to losses.The low carbon or net zero transition may also require ING to modify or implement new compliance systems,internal controls and procedures or governance frameworks. The integration and automation of internalgovernance, compliance, and disclosure and reporting frameworks across ING could lead to increasedoperational costs for ING and other execution and operational risks. The implementation cost of these systemsmay especially be higher in the near term as ING seeks to adapt its business, or address overlapping, duplicativeor conflicting regulatory or other requirements in this fast-developing area. Furthermore, ING’s ongoingimplementation of appropriate systems, controls and frameworks increasingly requires ING to develop adequateclimate change-related risk assessment and modelling capabilities (as there is currently no standard approach ormethodology available), and to collect customer, third party or other data. There are significant risks anduncertainties inherent in the development of new risk modelling methodologies and the collection of data,potentially resulting in systems or frameworks that could be inadequate, inaccurate or susceptible to incorrectcustomer, third party or other data. Any delay or failure in developing, implementing or meeting ING’s climate change-related commitments andregulatory requirements may have a material adverse impact on our business, financial condition, operating results and reputation, and lead to climate change or ESG-related investigations, enforcement proceedings or litigation
Natural and Human Disruptions - Risk 3
Added
ING’s business and operations are exposed to physical risks, including as a direct result of climate change
ING’s business and operations may be exposed to the impacts of physical risks arising from climate and weather-related events, including heatwaves, droughts, flooding, storms, rising sea levels, other extreme weather eventsor natural disasters, and to the impacts of physical risks arising from the environmental degradation, includingloss of biodiversity, water or resources scarcity, pollution or waste management. Such physical risks could disruptING’s business continuity and operations or impact ING’s premises or property portfolio, as well as its customers’property, business or other financial interests. These risks could potentially result in impairing asset values,financial losses, declining creditworthiness of customers and increased defaults, delinquencies, write-offs andimpairment charges in ING’s portfolio, etc. In particular, changing climate patterns resulting in more frequent andextreme weather events, such as the severe flooding that occurred in Western Europe in July 2021 or the long-lasting bushfires in Australia in February 2021, could lead to unexpected business interruptions or losses for ING or its customers. For a description of physical risks to our operations and business other than resulting from natural disasters as aresult of climate change, see “–Operational and IT risks, such as systems disruptions or failures, breaches ofsecurity, cyber attacks, human error, changes in operational practices, inadequate controls including in respect ofthird parties with which we do business or outbreaks of communicable diseases may adversely impact our reputation, business and results” above.
Capital Markets3 | 7.7%
Capital Markets - Risk 1
Market conditions, including those observed over the past few years, and the application of IFRS9 may increase the risk of loans being impaired and have a negative effect on our results and financial condition
We are exposed to the risk that our borrowers (including sovereigns) may not repay their loans according to theircontractual terms and that the collateral securing the payment of these loans may be insufficient. We may seeadverse changes in the credit quality of our borrowers and counterparties, for example, as a result of theirinability to refinance their indebtedness, with increasing delinquencies, defaults and insolvencies across a rangeof sectors. This may lead to impairment charges on loans and other assets, higher costs and additions to loan lossprovisions. A significant increase in the size of our provision for loan losses could have a material adverse effecton our business, results and financial condition. Also see above under the heading “–ING’s business, results andfinancial condition have been, and likely will continue to be adversely affected by the Covid-19 pandemic”. As setout there, we expect to be affected by the Covid-19 pandemic through its impact on, among others, the financialcondition of our customers or other counterparties
Capital Markets - Risk 2
The default of a major market participant could disrupt the markets and may have an adverse effect on our business, results and financial condition
Within the financial services industry, the severe distress or default of any one institution (including sovereignsand 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 actualoccurrence of such a default could have a material adverse impact on ING. Such distress of, or default by, a majorfinancial institution could disrupt markets or clearance and settlement systems and lead to a chain of defaults byother financial institutions, since the commercial and financial soundness of many financial institutions may beclosely related as a result of credit, trading, clearing or other relationships. Also the perceived lack ofcreditworthiness of a sovereign or a major financial institution (or a default by any such entity) may lead tomarket-wide liquidity problems and losses or defaults by us or by other institutions. This risk is sometimesreferred to as ‘systemic risk’ and may adversely affect financial intermediaries, such as clearing agencies, clearinghouses, banks, securities firms and exchanges with whom we interact on a daily basis and financial instrumentsof sovereigns in which we invest. Systemic risk could impact ING directly, by exposing it to material credit losseson transactions with defaulting counterparties or indirectly by significantly reducing the available market liquidityon which ING and its lending customers depend to fund their operations and/or leading to a write down of loansor securities held by ING. In addition, ING may also be faced with additional open market risk for which hedgingor mitigation strategies may not be available or effective (either by hedges eliminated by defaultingcounterparties, or reduce market liquidity). Systemic risk could have a material adverse effect on our ability toraise new funding and on our business, results and financial condition. In addition, such distress or failure couldimpact future product sales as a potential result of reduced confidence in the financial services industry
Capital Markets - Risk 3
We depend on the capital and credit markets, as well as customer deposits, to provide theliquidity and capital required to fund our operations, and adverse conditions in the capital andcredit markets, or significant withdrawals of customer deposits, may impact our liquidity,borrowing and capital positions, as well as the cost of liquidity, borrowings and capital.
Adverse capital market conditions have in the past affected, and may in the future affect, our cost of borrowedfunds and our ability to borrow on a secured and unsecured basis, thereby impacting our ability to supportand/or grow our businesses. Furthermore, although interest rates are at or near historically low levels, since therecent financial crisis, we have experienced increased funding costs due in part to the withdrawal of perceivedgovernment support of such institutions in the event of future financial crises. In addition, liquidity in thefinancial markets has also been negatively impacted as market participants and market practices and structuresadjust to new regulations.We need liquidity to fund new and recurring business, to pay our operating expenses, interest on our debt anddividends on our capital stock, maintain our securities lending activities and replace certain maturing liabilities.Without sufficient liquidity, we will be forced to curtail our operations and our business will suffer. The principalsources of our funding include a variety of short-and long-term instruments, including deposit fund, repurchaseagreements, commercial paper, medium- and long-term debt, subordinated debt securities, capital securities andshareholders’ equity.In addition, because we rely on customer deposits to fund our business and operations, the confidence ofcustomers in financial institutions may be tested in a manner that may adversely impact our liquidity and capitalposition. Consumer confidence in financial institutions may, for example, decrease due to our or our competitors’failure to communicate to customers the terms of, and the benefits to customers of, complex or high-feefinancial products. Reduced confidence could have an adverse effect on our liquidity and capital position throughwithdrawal of deposits, in addition to our revenues and results. Because a significant percentage of our customerdeposit base is originated via Internet banking, a loss of customer confidence may result in a rapid withdrawal of deposits over the Internet. In the event that our current resources do not satisfy our needs, we may need to seek additional financing. Theavailability of additional financing will depend on a variety of factors, such as market conditions, the generalavailability of credit, the volume of trading activities, the overall availability of credit to the financial servicesindustry, our credit ratings and credit capacity, as well as the possibility that customers or lenders could developa negative perception of our long- or short-term financial prospects. Also see under the heading “Ratings areimportant to our business for a number of reasons, and a downgrade or a potential downgrade in our creditratings could have an adverse impact on our results and net results”. Similarly, our access to funds may be limitedif regulatory authorities or rating agencies take negative actions against us. If our internal sources of liquidityprove to be insufficient, there is a risk that we may not be able to successfully obtain additional financing onfavourable terms, or at all. Any actions we might take to access financing may, in turn, cause rating agencies tore-evaluate our ratings.Disruptions, uncertainty or volatility in the capital and credit markets may also limit our access to capital. Suchmarket conditions may in the future limit our ability to raise additional capital to support business growth, or tocounterbalance the consequences of losses or increased regulatory capital and rating agency capitalrequirements. This could force us to (i) delay raising capital, (ii) reduce, cancel or postpone payment of dividendson our shares, (iii) reduce, cancel or postpone interest payments on our other securities, (iv) issue capital ofdifferent types or under different terms than we would otherwise, or (v) incur a higher cost of capital than in amore stable market environment. This would have the potential to decrease both our profitability and ourfinancial flexibility. Our results, financial condition, cash flows, regulatory capital and rating agency capitalposition could be materially adversely affected by disruptions in the financial markets.Furthermore, regulatory liquidity requirements in certain jurisdictions in which we operate are remain stringent,undermining our efforts to maintain centralised management of our liquidity. These developments may causetrapped pools of liquidity and capital, resulting in inefficiencies in the cost of managing our liquidity and solvency,and hinder our efforts to integrate our balance sheet. An example of such trapped liquidity includes ouroperations in Germany where German regulations impose separate liquidity requirements that restrict ING’sability to move a liquidity surplus out of the German subsidiary.
Legal & Regulatory
Total Risks: 9/39 (23%)Above Sector Average
Regulation6 | 15.4%
Regulation - Risk 1
We are subject to the regulatory supervision of the ECB and other regulators with extensive supervisory and investigatory powers.
In its capacity as principal prudential supervisor in the EU, the ECB has extensive supervisory and investigatorypowers, including the ability to issue requests for information, to conduct regulatory investigations and on-siteinspections, and to impose monetary and other sanctions. For example, under the Single Supervisory Mechanism(SSM), the regulators with jurisdiction over the Group, including the ECB, may conduct stress tests and havediscretion to impose capital surcharges on financial institutions for risks that are not otherwise recognised in risk-weighted assets or other surcharges depending on the individual situation of the bank and take or require othermeasures, such as restrictions on or changes to the Group’s business. Competent authorities may also, if theGroup fails to comply with regulatory requirements, in particular with supervisory actions, minimum capitalrequirements (including buffer requirements) or with liquidity requirements, or if there are shortcomings in itsgovernance and risk management processes, prohibit the Group from making dividend payments to shareholdersor distributions to holders of its regulatory capital instruments. Generally, a failure to comply with prudential orconduct regulations could have a material adverse effect on the Group’s business, results and financial condition.
Regulation - Risk 2
Failure to meet minimum capital and other prudential regulatory requirements as applicable tous from time to time may have a material adverse effect on our business, results and financialcondition and on our ability to make payments on certain of our securities.
ING is subject to a variety of regulations that require us to comply with minimum requirements for capital (ownfunds) and additional loss absorbing capacity, as well as for liquidity, and to comply with leverage restrictions. Inaddition, such capital, liquidity and leverage requirements and their application and interpretation may change.Any changes may require us to maintain more capital or to raise a different type of capital by disqualifyingexisting capital instruments from continued inclusion in regulatory capital, requiring replacement with newcapital instruments that meet the new criteria. Sometimes changes are introduced subject to a transitionalperiod during which the new requirements are being phased in, gradually progressing to a fully phased-in, orfully-loaded, application of the requirements. Any failure to comply with these requirements, or to adapt to changes in such requirements, may have a materialadverse effect on our business, results and financial condition, and may require us to seek additional capital.Failures to meet minimum capital or other prudential requirements may also result in ING being prohibited frommaking payments on certain of our securities. Because implementation phases and transposition into EU ornational regulation where required may often involve a lengthy period, the impact of changes in capital, liquidityand leverage regulations on our business, results and financial condition, and on our ability to make payments on certain of our securities, is often unclear For further discussion of the impact of minimum capital and other prudential regulatory requirements on ING,see “Item 4. Information on the Company—Regulation and Supervision—Regulatory Developments—Basel III andEuropean Union Standards as currently applied by ING Group.”
Regulation - Risk 3
Our US commodities and derivatives business is subject to CFTC and SEC regulation under the Dodd-Frank Act.
Our affiliate ING Capital Markets LLC is registered with the Commodity Futures Trading Commission (“CFTC”) as aswap dealer and is subject to CFTC regulation of the off-exchange derivatives market pursuant to Title VII of theU.S. Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”). Operating as a swap dealerrequires compliance with CFTC regulatory requirements, which may be burdensome, impose additionalcompliance costs and could adversely affect the profitability of this business, as well as exposing ING to the riskof non-compliance with these regulations.ING Capital Markets LLC is also registered with the SEC as a security-based swap dealer pursuant to Dodd-Frankand SEC regulations enacted thereunder effective 1 November 2021. While ING Capital Markets LLC, as asecurity-based swap dealer, is required to comply with SEC rules with respect to most of these requirements, SECrules have permitted an “Alternative Compliance Mechanism” that allows for compliance, subject to eligibilityrequirements, with CFTC capital and margin rules applying to swap dealers in lieu of SEC capital and margin rulesapplying to security-based swap dealers. ING Capital Markets LLC has elected to use the Alternative ComplianceMechanism. However, should ING Capital Markets LLC in the future be ineligible for the “Alternative ComplianceMechanism” it would be subject to SEC capital and margin security-based swap dealer rules instead of the CFTCcapital and margin security-based swap dealer rules. SEC registration may increase ING Capital Markets LLC’soperational costs as a result of compliance, margin, capital and other requirements, and result in a substantialportion or all of ING’s security-based swap activities with U.S. persons being conducted through ING CapitalMarkets LLC. These registration and related requirements may also reduce trading activity, reduce marketliquidity and increase volatility in the relevant markets.In addition, new position limits under Dodd-Frank applicable to the derivatives market generally for futurescontracts based on any of twenty-five commodity futures contracts on physical commodities, which to all marketparticipants, could limit ING’s position sizes in these futures contracts and similarly limit the ability ofcounterparties to utilize certain of our products to the extent hedging exemptions from the position limits areunavailable. In addition, position limits on swaps on the same physical commodities will become effective in January 2023, which could further limit the ability of ING and its counterparties to enter into such swaps. Suchregulation of the derivative markets and market participants will likely result in increased cost of hedging andother trading activities, both for ING and its customers, which could expose our business to greater risk and couldreduce the size and profitability of our customer business. The imposition of these regulatory restrictions andrequirements, could also result in reduced market liquidity, which could in turn increase market volatility and therisks and costs of hedging and other trading activities. Any of the foregoing factors, and any further regulatory developments with respect to commodities andderivatives, could have a material impact on our business, results and financial condition.For further discussion of the impact of regulation of commodities and derivatives on ING, see “Item 4.Information on the Company—Regulation and Supervision—Regulatory Developments—Dodd-Frank Act and other US Regulations.”
Regulation - Risk 4
We are subject to additional legal and regulatory risk in certain countries where we operate withless developed or predictable legal and regulatory frameworks.
In certain countries in which we operate, judiciary and dispute resolution systems may be less effective. As aresult, in case of a breach of contract, we may have difficulties in making and enforcing claims against contractualcounterparties and, if claims are made against us, we might encounter difficulties in mounting a defence againstsuch allegations. If we become party to legal proceedings in a market with an insufficiently developed judicialsystem, it could have an adverse effect on our operations and net results.In addition, as a result of our operations in certain countries, we are subject to risks of possible nationalisation,expropriation, price controls, exchange controls and other restrictive government actions, as well as the outbreakof hostilities and or war, in these markets. In particular, we have wholesale banking activities in both Russia andUkraine, as well as investments in Russia, some of which are denominated in local currency, and othercounterparties located in Russia. Furthermore, the current economic environment in certain countries in which we operate may increase the likelihood for regulatory initiatives to enhance consumer protection or to protecthomeowners from foreclosures. Any such regulatory initiative could have an adverse impact on our ability toprotect our economic interest, for instance in the event of defaults on residential mortgages.
Regulation - Risk 5
Changes in laws and/or regulations governing financial services or financial institutions or theapplication of such laws and/or regulations may increase our operating costs and limit our activities.
We are subject to detailed banking laws and financial regulation in the jurisdictions in which we conductbusiness. Regulation of the industries in which we operate is becoming increasingly more extensive and complex,while also attracting supervisory scrutiny. Compliance with applicable and new laws and regulations is resources-intensive, and may materially increase our operating costs. Moreover, these regulations intended to protect ourcustomers, markets and society as a whole and can limit our activities, among others, through stricter net capital, market conduct and transparency requirements and restrictions on the businesses in which we can operate orinvest.Our revenues and profitability and those of our industry have been and will continue to be impacted byrequirements relating to capital, additional loss-absorbing capacity, leverage, minimum liquidity and long-termfunding levels, requirements related to resolution and recovery planning, derivatives clearing and margin rulesand levels of regulatory oversight, as well as limitations on which and, if permitted, how certain business activities may be carried out by financial institutions.
Regulation - Risk 6
Non-compliance with laws and/or regulations concerning financial services or financialinstitutions, including with respect to financial economic crimes, could result in fines and otherliabilities, penalties or consequences for us, which could materially affect our business and reduce our profitability
ING has faced, and in the future may continue to face, the risk of consequences in connection with non-compliance with applicable laws and regulations. For additional information on legal proceedings, see Note 46‘Legal proceedings’ to the consolidated financial statements. There are a number of risks in areas whereapplicable regulations may be unclear, subject to multiple interpretations or under development, or whereregulations may conflict with one another, or where regulators revise their previous guidance or courts overturnprevious rulings, which could result in our failure to meet applicable standards. Regulators and other authoritieshave the power to bring administrative or judicial proceedings against us, which could result, among other things,in suspension or revocation of our licenses, cease and desist orders, fines, civil penalties, criminal penalties orother disciplinary action, which could materially harm our results and financial condition. If we fail to address, orappear to fail to address, any of these matters appropriately, our reputation could be harmed and we could besubject to additional legal risk, which could, in turn, increase the size and number of claims and damages broughtagainst us or subject us to enforcement actions, fines and penalties.Furthermore, as a financial institution, we are exposed to the risk of unintentional involvement in criminalactivity in connection with the commission of financial economic crimes, including with respect to moneylaundering and the funding of terrorist and other criminal activities. The failure or perceived failure by us tocomply with legal and regulatory requirements with respect to financial economic crimes may result in adversepublicity, claims and allegations, litigation and regulatory investigations and sanctions, which may have a materialadverse effect on our business, results, financial condition and/or prospects in any given period. For furtherdiscussion of the impact of litigation, enforcement proceedings, investigations or other regulatory actions withrespect to financial economic crimes, see “– We may be subject to litigation, enforcement proceedings,investigations or other regulatory actions, and adverse publicity” below.
Litigation & Legal Liabilities1 | 2.6%
Litigation & Legal Liabilities - Risk 1
We may be subject to litigation, enforcement proceedings, investigations or other regulatory actions, and adverse publicity.
We are involved in governmental, regulatory, arbitration and legal proceedings and investigations involvingclaims by and against us which arise in the ordinary course of our businesses, including in connection with ouractivities as financial services provider, employer, investor and taxpayer. As a financial institution, we are subjectto specific laws and regulations governing financial services or financial institutions. See “Risks related to theregulation and supervision of the Group– Changes in laws and/or regulations governing financial services orfinancial institutions or the application of such laws and/or regulations may increase our operating costs and limitour activities” above. Financial reporting irregularities involving other large and well-known companies, possiblefindings of government authorities in various jurisdictions which are investigating several rate-setting processes,notifications made by whistleblowers, increasing regulatory and law enforcement scrutiny of ‘know yourcustomer’ anti-money laundering, tax evasion, prohibited transactions with countries or persons subject tosanctions, and bribery or other anti-corruption measures and anti-terrorist-financing procedures and theireffectiveness, regulatory investigations of the banking industry, and litigation that arises from the failure orperceived failure by us to comply with legal, regulatory, tax and compliance requirements could result in adversepublicity and reputational harm, lead to increased regulatory supervision, affect our ability to attract and retaincustomers and maintain access to the capital markets, result in cease and desist orders, claims, enforcementactions, fines and civil and criminal penalties, other disciplinary action or have other material adverse effects onus in ways that are not predictable. With respect to sanctions, beginning in February 2022, the EU, UK and theUS, in a coordinated effort joined by several other countries, imposed a variety of new sanctions with respect toRussia and various Russia-related parties. Despite significant similarities between these Russia-related sanctionsprogrammes, there are notable differences between the EU, UK and US sanctions programmes, which may continue to evolve and are expected to require ING to implement new control measures with related costs andrisks of non-compliance. While various sanctions include grace periods before full compliance is required, there isno guarantee that ING will be able to implement all required procedures within the applicable grace periods. Inaddition, some claims and allegations may be brought by or on behalf of a class and claimants may seek large orindeterminate amounts of damages, including compensatory, liquidated, treble and punitive damages. Ourreserves for litigation liabilities may prove to be inadequate. Claims and allegations, should they become public,need not be well founded, true or successful to have a negative impact on our reputation. In addition, pressreports and other public statements that assert some form of wrongdoing could result in inquiries orinvestigations by regulators, legislators and law enforcement officials, and responding to these inquiries andinvestigations, regardless of their ultimate outcome, is time consuming and expensive. Adverse publicity, claimsand allegations, litigation and regulatory investigations and sanctions may have a material adverse effect on ourbusiness, results, financial condition and/or prospects in any given period.
Taxation & Government Incentives2 | 5.1%
Taxation & Government Incentives - Risk 1
We are subject to different tax regulations in each of the jurisdictions where we conductbusiness, and are exposed to changes in tax laws, and risks of non-compliance with or proceedings or investigations with respect to, tax laws.
Changes in tax laws (including case law) and tax treaties (including the termination thereof) could increase ourtaxes and our effective tax rates and could materially impact our tax receivables and liabilities as well as deferredtax assets and deferred tax liabilities, which could have a material adverse effect on our business, results andfinancial condition. Changes in tax laws could also make certain ING products less attractive, which could haveadverse consequences for our businesses and results. On 7 June 2021, the Dutch government received a formalnotice of denunciation of the Dutch-Russian tax treaty from Russia, and as a result, the tax treaty was terminatedas of 1 January 2022. The termination of the Dutch-Russian tax treaty or any other similar developments mayhave adverse effects on ING and ING’s customers. Because of the geographic spread of its business, ING may be subject to tax audits, investigations and proceduresin numerous jurisdictions at any point in time. Although we believe that we have adequately provided for all ourtax positions, the ultimate resolution of these audits, investigations and procedures may result in liabilities whichare different from the amounts recognized. In addition, increased bank taxes in countries where the Group isactive result in increased taxes on ING’s banking operations, which could negatively impact our operations,financial condition and liquidity
Taxation & Government Incentives - Risk 2
We may be subject to withholding tax if we fail to comply with the Foreign Account TaxCompliance Act (“FATCA”) and other US withholding tax regulations
Due to the nature of its business, ING is subject to various provisions of US tax law. These include FATCA, whichrequires ING to provide certain information for the US Internal Revenue Service (“IRS”), and the QualifiedIntermediary (“QI”) requirements, which require withholding tax on certain US-source payments. Failure tocomply with FATCA and/or QI requirements and regulations could harm our reputation and could subject theGroup to enforcement actions, fines and penalties, which could have a material adverse effect on our business,reputation, revenues, results, financial condition and prospects. For further discussion of FATCA and QIrequirements with respect to ING, see “Item 4. Information on the Company—Regulation and Supervision—KYCRequirements.”
Production
Total Risks: 4/39 (10%)Above Sector Average
Manufacturing1 | 2.6%
Manufacturing - Risk 1
Added
ING may be unable to adapt its products and services to meet changing customer behaviour and demand, including as a result of ESG-related matters.
Customers or other counterparties may increasingly assess sustainability or other ESG-related matters in theireconomic decisions. For instance, customers may choose investment products or services based on sustainabilityor other ESG criteria, or may look at a financial institution’s ESG-related lending strategy when choosing to makedeposits. To remain competitive and to safeguard its reputation, ING is required to continuously adapt itsbusiness strategy, products and services to respond to emerging, increasing or changing sustainability and otherESG-related demands from customers, investors and other stakeholders. However, there is no guarantee thatING’s current or future products or services will meet applicable ESG-related regulatory requirements, customerpreferences or investor expectations. For further information regarding the alignment of ING’s lending portfolio with its climate-related goals, see“Item 4. – Information on the Company – Business Overview – Responsible finance” below.
Employment / Personnel2 | 5.1%
Employment / Personnel - Risk 1
We may incur further liabilities in respect of our defined benefit retirement plans if the value ofplan assets is not sufficient to cover potential obligations, including as a result of differencesbetween actual results and underlying actuarial assumptions and models.
ING Group companies operate various defined benefit retirement plans covering the post-employment benefitsof a number of our employees. The liability recognised in our consolidated balance sheet in respect of ourdefined benefit plans is the present value of the defined benefit obligations at the balance sheet date, less thefair value of each plan’s assets, together with adjustments for unrecognised actuarial gains and losses andunrecognised past service costs. We determine our defined benefit plan obligations based on internal andexternal actuarial models and calculations using the projected unit credit method. Inherent in these actuarialmodels are assumptions, including discount rates, rates of increase in future salary and benefit levels, mortalityrates and consumer price index. These assumptions are based on available market data and are updated annually. Nevertheless, the actuarial assumptions may differ significantly from actual results due to changes inmarket conditions, economic and mortality trends and other assumptions. Any changes in these assumptionscould have a significant impact on our present and future liabilities and costs associated with our defined benefit plans
Employment / Personnel - Risk 2
An inability to retain or attract key personnel may affect our business and results
ING Group relies to a considerable extent on the quality of its senior management, such as members of theexecutive committee, and management in the jurisdictions which are material to ING’s business and operations.The success of ING Group’s operations is dependent, among other things, on its ability to attract and retain highlyqualified personnel. Competition for key personnel in most countries in which ING Group operates, and globallyfor senior management, is intense. ING Group’s ability to attract and retain key personnel, in senior managementand in particular areas such as technology and operational management, client relationship management,finance, risk and product development, is dependent on a number of factors, including prevailing marketconditions and compensation packages offered by companies competing for the same talent.The (increasing) restrictions on remuneration, plus the public and political scrutiny especially in the Netherlands,will continue to have an impact on existing ING Group remuneration policies and individual remunerationpackages for personnel. For example, under the EU’s amended Shareholder Rights Directive, known as ‘SRD II’,which came into effect on June 10, 2019, ING is required to hold a shareholder (binding) vote on ING’s ExecutiveBoard remuneration policy and Supervisory Board remuneration policy at least every four years. Furthermore theshareholders have an advisory vote on ING’s remuneration report annually. This may restrict our ability to offercompetitive compensation compared with companies (financial and/or non-financial) that are not subject to suchrestrictions and it could adversely affect ING Group’s ability to retain or attract key personnel, which, in turn, may affect our business and results.
Supply Chain1 | 2.6%
Supply Chain - Risk 1
We may be unable to manage our risks successfully through derivatives.
We employ various economic hedging strategies with the objective of mitigating the market risks that areinherent in our business and operations. These risks include currency fluctuations, changes in the fair value of our investments, the impact of interest rates, equity markets and credit spread changes, the occurrence of creditdefaults and changes in client behaviour. We seek to control these risks by, among other things, entering into anumber of derivative instruments, such as swaps, options, futures and forward contracts, including, from time totime, macro hedges for parts of our business, either directly as a counterparty or as a credit support provider toaffiliate counterparties. Developing an effective strategy for dealing with these risks is complex, and no strategycan completely insulate us from risks associated with those fluctuations. Our hedging strategies also rely onassumptions and projections regarding our assets, liabilities, general market factors and the creditworthiness ofour counterparties that may prove to be incorrect or prove to be inadequate. Accordingly, our hedging activitiesmay not have the desired beneficial impact on our results or financial condition. Poorly designed strategies orimproperly executed transactions could actually increase our risks and losses. Hedging strategies involvetransaction costs and other costs, and if we terminate a hedging arrangement, we may also be required to payadditional costs, such as transaction fees or breakage costs. There have been periods in the past, and it is likelythat there will be periods in the future, during which we have incurred or may incur losses on transactions,possibly significant, after taking into account our hedging strategies. Further, the nature and timing of ourhedging transactions could actually increase our risk and losses. Hedging instruments we use to manage productand other risks might not perform as intended or expected, which could result in higher (un)realised losses, suchas credit value adjustment risks or unexpected P&L effects, and unanticipated cash needs to collateralise or settlesuch transactions. Adverse market conditions can limit the availability and increase the costs of hedginginstruments, and such costs may not be recovered in the pricing of the underlying products being hedged. Inaddition, hedging counterparties may fail to perform their obligations, resulting in unhedged exposures andlosses on positions that are not collateralised. As such, our hedging strategies and the derivatives that we use ormay use may not adequately mitigate or offset the risks they intend to cover, and our hedging transactions mayresult in losses.Our hedging strategy additionally relies on the assumption that hedging counterparties remain able and willing toprovide the hedges required by our strategy. Increased regulation, market shocks, worsening market conditions(whether due to the ongoing euro crisis or otherwise), and/or other factors that affect or are perceived to affectthe financial condition, liquidity and creditworthiness of ING may reduce the ability and/or willingness of suchcounterparties to engage in hedging contracts with us and/or other parties, affecting our overall ability to hedgeour risks and adversely affecting our business, results and financial condition
Tech & Innovation
Total Risks: 3/39 (8%)Above Sector Average
Trade Secrets1 | 2.6%
Trade Secrets - Risk 1
Added
We may not always be able to protect our intellectual property developed in our products andservices and may be subject to infringement claims, which could adversely impact our corebusiness, inhibit efforts to monetize our internal innovations and restrict our ability to capitalize on future opportunities
In the conduct of our business, we rely on a combination of contractual rights with third parties and copyright,trademark, trade name, patent and trade secret laws to establish and protect our intellectual property, which wedevelop in connection with our products and services. Third parties may infringe or misappropriate ourintellectual property. We may have to litigate to enforce and protect our copyrights, trademarks, trade names,patents, trade secrets and know-how or to determine their scope, validity or enforceability. In that event, wemay be required to incur significant costs, and our efforts may not prove successful. The inability to secure orprotect our intellectual property assets could have an adverse effect on our core business and our ability tocompete, including through the monetization of our internal innovations We may also be subject to claims made by third parties for (1) patent, trademark or copyright infringement, (2)breach of copyright, trademark or licence usage rights, or (3) misappropriation of trade secrets. Any such claimsand any resulting litigation could result in significant expense and liability for damages. If we were found to haveinfringed or misappropriated a third-party patent or other intellectual property right, we could in somecircumstances be enjoined from providing certain products or services to our customers or from utilizing andbenefiting from certain methods, processes, copyrights, trademarks, trade secrets or licences. Alternatively, wecould be required to enter into costly licensing arrangements with third parties or to implement a costlyworkaround. Any of these scenarios could have a material adverse effect on our business and results and could restrict our ability to pursue future business opportunities.
Cyber Security1 | 2.6%
Cyber Security - Risk 1
We are subject to increasing risks related to cybercrime and compliance with cyber security regulation
Like other financial institutions and global companies, we are regularly the target of cyber attacks, which is aspecific risk to ING as a result of its strategic focus on technology and innovation. In particular, threats fromDistributed Denial of Service (‘DDoS’), targeted attacks (also called Advanced Persistent Threats) andRansomware intensify worldwide, and attempts to gain unauthorised access and the techniques used for suchattacks are increasingly sophisticated. We have faced, and expect to continue to face, an increasing number ofcyber attacks (both successful and unsuccessful) as we have further digitalized. This includes the continuingexpansion of our mobile- and other internet-based products and services, as well as our usage and reliance oncloud technology.Cybersecurity, customer data and data privacy have become the subject of increasing legislative and regulatoryfocus. The EU’s second Payment Services Directive (‘PSD2’) and GDPR are examples of such regulations. In certainlocations where ING is active, there are additional local regulatory requirements and legislation on top of EUregulations that must be followed for business conducted in that jurisdiction. Some of these legislations andregulations may be conflicting due to local regulatory interpretations. We may become subject to new EU andlocal legislation or regulation concerning cybersecurity, security of customer data in general or the privacy ofinformation we may store or maintain. Compliance with such new legislation or regulation could increase theGroup’s compliance cost. Failure to comply with new and existing legislation or regulation could harm ourreputation and could subject the Group to enforcement actions, fines and penalties. ING may be exposed to the risks of misappropriation, unauthorised access, computer viruses or other maliciouscode, cyber attacks and other external attacks or internal breaches that could have a security impact. Theseevents could also jeopardise our confidential information or that of our clients or our counterparties and thiscould be exacerbated by the increase in data protection requirements as a result of GDPR. These events canpotentially result in financial loss and harm to our reputation, hinder our operational effectiveness, result inregulatory censure, compensation costs or fines resulting from regulatory investigations and could have amaterial adverse effect on our business, reputation, revenues, results, financial condition and prospects. Evenwhen we are successful in defending against cyber attacks, such defence may consume significant resources or impose significant additional costs on ING
Technology1 | 2.6%
Technology - Risk 1
Changed
Operational and IT risks, such as systems disruptions or failures, breaches of security, cyberattacks, human error, changes in operational practices, inadequate controls including in respectof third parties with which we do business or outbreaks of communicable diseases may adversely impact our reputation, business and results
We face the risk that the design and operating effectiveness of our controls and procedures may prove to beinadequate. Operational and IT risks are inherent to our business. Our businesses depend on the ability toprocess and report a large number of transactions efficiently and accurately. In addition, we routinely transmit,receive and store personal, confidential and proprietary information by email and other electronic means.Although we endeavour to safeguard our systems and processes, losses can result from inadequately trained orskilled personnel, IT failures (including due to a computer virus or a failure to anticipate or prevent cyber attacksor other attempts to gain unauthorised access to digital systems for purposes of misappropriating assets orsensitive information, corrupting data, or impairing operational performance, or security breaches by thirdparties), inadequate or failed internal control processes and systems, regulatory breaches, human errors,employee misconduct, including fraud, or from natural disasters or other external events that interrupt normalbusiness operations. Such losses may adversely affect our reputation, business and results. We depend on thesecure processing, storage and transmission of confidential and other information in our computer systems andnetworks. The equipment and software used in our computer systems and networks may not always be capableof processing, storing or transmitting information as expected. Despite our business continuity plans andprocedures, certain of our computer systems and networks may have insufficient recovery capabilities in theevent of a malfunction or loss of data. We are consistently managing and monitoring our IT risk profile globally.ING is subject to increasing regulatory requirements including EU General Data Protection Regulation (‘GDPR’)and EU Payment Services Directive (‘PSD2’). Failure to appropriately manage and monitor our IT risk profile couldaffect our ability to comply with these regulatory requirements, to securely and efficiently serve our clients or totimely, completely or accurately process, store and transmit information, and may adversely impact ourreputation, business and results. For further description of the particular risks associated with cybercrime, whichis a specific risk to ING as a result of its strategic focus on technology and innovation, see “–We are subject toincreasing risks related to cybercrime and compliance with cybersecurity regulation” below. Widespread outbreaks of communicable diseases may impact the health of our employees, increasingabsenteeism, or may cause a significant increase in the utilisation of health benefits offered to our employees,either or both of which could adversely impact our business. Also see above under the heading “–ING’s business,results and financial condition have been, and likely will continue to be adversely affected by the Covid-19pandemic”. As set out there, we expect to be affected by the Covid-19 pandemic through its impact on, amongothers, our employees. In addition, other events including unforeseeable and/or catastrophic events can lead toan abrupt interruption of activities, and our operations may be subject to losses resulting from such disruptions.Losses can result from destruction or impairment of property, financial assets, trading positions, and the loss ofkey personnel. If our business continuity plans are not able to be implemented, are not effective or do notsufficiently take such events into account, losses may increase further
Ability to Sell
Total Risks: 2/39 (5%)Below Sector Average
Competition1 | 2.6%
Competition - Risk 1
Because we operate in highly competitive markets, including our home market, we may not beable to increase or maintain our market share, which may have an adverse effect on our results
There is substantial competition in the Netherlands and the other countries in which we do business for the typesof wholesale banking, retail banking, investment banking and other products and services we provide. Customerloyalty and retention can be influenced by a number of factors, including brand recognition, reputation, relativeservice levels, the prices and attributes of products and services, scope of distribution, credit ratings and actionstaken by existing or new competitors (including non-bank or financial technology competitors). A decline in ourcompetitive position as to one or more of these factors could adversely impact our ability to maintain or furtherincrease our market share, which would adversely affect our results. Such competition is most pronounced in ourmore mature markets of the Netherlands, Belgium, the rest of Western Europe and Australia. In recent years,however, competition in emerging markets, such as Asia and Central and Eastern Europe, has also increased aslarge financial services companies from more developed countries have sought to establish themselves inmarkets which are perceived to offer higher growth potential, and as local institutions have become moresophisticated and competitive and proceeded to form alliances, mergers or strategic relationships with ourcompetitors. The Netherlands is our largest market. Our main competitors in the banking sector in theNetherlands are ABN AMRO Bank and Rabobank.Competition could also increase due to new entrants (including non-bank and financial technology competitors)in the markets that may have new operating models that are not burdened by potentially costly legacyoperations and that are subject to reduced regulation. New entrants may rely on new technologies, advanceddata and analytic tools, lower cost to serve, reduced regulatory burden and/or faster processes in order tochallenge traditional banks. Developments in technology has also accelerated the use of new business models and ING may not be successful in adapting to this pace of change or may incur significant costs in adapting itsbusiness and operations to meet such changes. For example, new business models have been observed in retailpayments, consumer and commercial lending (such as peer-to-peer lending), foreign exchange and low-costinvestment advisory services. In particular, the emergence of disintermediation in the financial sector resultingfrom new banking, lending and payment solutions offered by rapidly evolving incumbents, challengers and newentrants, in particular with respect to payment services and products, and the introduction of disruptivetechnology may impede our ability to grow or retain our market share and impact our revenues and profitability.Increasing competition in the markets in which we operate (including from non-banks and financial technologycompetitors) may significantly impact our results if we are unable to match the products and services offered byour competitors. Future economic turmoil may accelerate additional consolidation activity. Over time, certainsectors of the financial services industry have become more concentrated, as institutions involved in a broadrange of financial services have been acquired by or merged into other firms or have declared bankruptcy. Thesedevelopments could result in our competitors gaining greater access to capital and liquidity, expanding theirranges of products and services, or gaining geographic diversity. We may experience pricing pressures as a resultof these factors in the event that some of our competitors seek to increase market share by reducing prices,which may have a material adverse impact on our business, results and financial condition
Sales & Marketing1 | 2.6%
Sales & Marketing - Risk 1
Changed
ING is exposed to the risk of claims from customers or stakeholders who feel misled or treated unfairly because of advice or information received.
Our products and services, including banking products and advice services for third-party products are exposedto claims from customers who might allege that they have received insufficient advice or misleading informationfrom advisers (both internal and external) as to which products were most appropriate for them, or that theterms and conditions of the products, the nature of the products or the circumstances under which the productswere sold, were misrepresented to them. When new financial products are brought to the market, ING engagesin a multidisciplinary product approval process in connection with the development and distribution of suchproducts, including production of appropriate marketing and communication materials. Notwithstanding theseprocesses, customers may make claims against ING if the products do not meet their expectations , either at thepurchase/execution of the product and/or through the life of the product. Customer protection regulations, aswell as changes in interpretation and perception by both the public at large and governmental authorities ofacceptable market practices, influence customer expectations.Products distributed through person-to-person sales forces have a higher exposure to such claims as the salesforces may provide face-to-face financial planning and advisory services. Complaints may also arise if customersfeel that they have not been treated reasonably or fairly, or that the duty of care has not been complied with.While a considerable amount of time and resources have been invested in reviewing and assessing historicalsales practices and products that were sold in the past, and in the maintenance of risk management, legal andcompliance procedures to monitor current sales practices, there can be no assurance that all of the issues associated with current and historical sales practices have been or will be identified, nor that any issues alreadyidentified will not be more widespread than presently estimated.The negative publicity associated with any sales practices, any compensation payable in respect of any suchissues and regulatory changes resulting from such issues, has had and could have a material adverse effect on ourreputation, business, results, financial condition and prospects. For additional information regarding legalproceedings or claims, see Note 46 ‘Legal proceedings’ to the consolidated financial statements.
See a full breakdown of risk according to category and subcategory. The list starts with the category with the most risk. Click on subcategories to read relevant extracts from the most recent report.

FAQ

What are “Risk Factors”?
Risk factors are any situations or occurrences that could make investing in a company risky.
    The Securities and Exchange Commission (SEC) requires that publicly traded companies disclose their most significant risk factors. This is so that potential investors can consider any risks before they make an investment.
      They also offer companies protection, as a company can use risk factors as liability protection. This could happen if a company underperforms and investors take legal action as a result.
        It is worth noting that smaller companies, that is those with a public float of under $75 million on the last business day, do not have to include risk factors in their 10-K and 10-Q forms, although some may choose to do so.
          How do companies disclose their risk factors?
          Publicly traded companies initially disclose their risk factors to the SEC through their S-1 filings as part of the IPO process.
            Additionally, companies must provide a complete list of risk factors in their Annual Reports (Form 10-K) or (Form 20-F) for “foreign private issuers”.
              Quarterly Reports also include a section on risk factors (Form 10-Q) where companies are only required to update any changes since the previous report.
                According to the SEC, risk factors should be reported concisely, logically and in “plain English” so investors can understand them.
                  How can I use TipRanks risk factors in my stock research?
                  Use the Risk Factors tab to get data about the risk factors of any company in which you are considering investing.
                    You can easily see the most significant risks a company is facing. Additionally, you can find out which risk factors a company has added, removed or adjusted since its previous disclosure. You can also see how a company’s risk factors compare to others in its sector.
                      Without reading company reports or participating in conference calls, you would most likely not have access to this sort of information, which is usually not included in press releases or other public announcements.
                        A simplified analysis of risk factors is unique to TipRanks.
                          What are all the risk factor categories?
                          TipRanks has identified 6 major categories of risk factors and a number of subcategories for each. You can see how these categories are broken down in the list below.
                          1. Financial & Corporate
                          • Accounting & Financial Operations - risks related to accounting loss, value of intangible assets, financial statements, value of intangible assets, financial reporting, estimates, guidance, company profitability, dividends, fluctuating results.
                          • Share Price & Shareholder Rights – risks related to things that impact share prices and the rights of shareholders, including analyst ratings, major shareholder activity, trade volatility, liquidity of shares, anti-takeover provisions, international listing, dual listing.
                          • Debt & Financing – risks related to debt, funding, financing and interest rates, financial investments.
                          • Corporate Activity and Growth – risks related to restructuring, M&As, joint ventures, execution of corporate strategy, strategic alliances.
                          2. Legal & Regulatory
                          • Litigation and Legal Liabilities – risks related to litigation/ lawsuits against the company.
                          • Regulation – risks related to compliance, GDPR, and new legislation.
                          • Environmental / Social – risks related to environmental regulation and to data privacy.
                          • Taxation & Government Incentives – risks related to taxation and changes in government incentives.
                          3. Production
                          • Costs – risks related to costs of production including commodity prices, future contracts, inventory.
                          • Supply Chain – risks related to the company’s suppliers.
                          • Manufacturing – risks related to the company’s manufacturing process including product quality and product recalls.
                          • Human Capital – risks related to recruitment, training and retention of key employees, employee relationships & unions labor disputes, pension, and post retirement benefits, medical, health and welfare benefits, employee misconduct, employee litigation.
                          4. Technology & Innovation
                          • Innovation / R&D – risks related to innovation and new product development.
                          • Technology – risks related to the company’s reliance on technology.
                          • Cyber Security – risks related to securing the company’s digital assets and from cyber attacks.
                          • Trade Secrets & Patents – risks related to the company’s ability to protect its intellectual property and to infringement claims against the company as well as piracy and unlicensed copying.
                          5. Ability to Sell
                          • Demand – risks related to the demand of the company’s goods and services including seasonality, reliance on key customers.
                          • Competition – risks related to the company’s competition including substitutes.
                          • Sales & Marketing – risks related to sales, marketing, and distribution channels, pricing, and market penetration.
                          • Brand & Reputation – risks related to the company’s brand and reputation.
                          6. Macro & Political
                          • Economy & Political Environment – risks related to changes in economic and political conditions.
                          • Natural and Human Disruptions – risks related to catastrophes, floods, storms, terror, earthquakes, coronavirus pandemic/COVID-19.
                          • International Operations – risks related to the global nature of the company.
                          • Capital Markets – risks related to exchange rates and trade, cryptocurrency.
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