A.M. Best Assigns Ratings to ING USA's Funding Agreement-Backed Securities Programs.

OLDWICK, N.J. -- A.M. Best Co. has assigned a rating of "aa-" to the two funding agreement-backed securities (FABS) programs sponsored by ING Group's (NYSE: ING) U.S. operations, ING USA (Atlanta, GA). A.M. Best has also assigned debt ratings of "aa-" to the outstanding notes issued, or those to be issued, under each program. The ratings currently have a negative outlook.

ING USA's recently established publicly-registered FABS program provides for the issuance of up to $5 billion of secured medium-term notes to both institutional and retail investors. The notes of each series will be issued by separate and distinct special purpose common law trusts, collectively known as the ING USA Global Funding Trusts. Each series of notes will be secured by a funding agreement issued by ING USA Annuity and Life Insurance Company (ING USA A&L) (Iowa). Based on A.M. Best's analysis of the FABS structure, the program and notes will carry the issuer credit rating (ICR) of "aa-" of ING USA A&L. This reflects A.M. Best's belief that, under Iowa Code, loss claims of principal and interest in respect of each funding agreement would be paid equally in priority (i.e. pari passu) with ING USA A&L's policyholders.

In 2002, ING USA established a $5 billion global debt issuance program sponsored by one of its key subsidiaries, Security Life of Denver Insurance Company (SLD) (Colorado). Through a Delaware statutory trust, ING Security Life Institutional Funding (ING SLIF), the group issued various series of notes to qualified institutional investors primarily in the United States, pursuant to Rule 144A. The notes of each series are secured by one or more funding agreements issued by SLD to ING SLIF. The ability of ING SLIF to meet its obligations with respect to a particular series of notes is indeed dependent upon SLD's ability to perform its obligations under each applicable funding agreement. However, investors in the notes have no direct contractual rights against SLD; their recourse is limited to the funding agreement securing the notes.

Based upon a review of the legal opinions and related documentation, A.M. Best has assigned a rating of "aa-" to the ING SLIF program and the notes issued hereunder. This reflects an opinion that in any liquidation proceeding relating to SLD, under current Colorado law, the claims with respect to payments of principal and interest under each funding agreement would be accorded a priority in liquidation equal to that of policyholders of SLD and superior to the claims of general unsecured creditors. Therefore, in assigning the ICRs above, A.M. Best believes that investors in ING USA's FABS are exposed to the inherent credit, liquidity and business risks of the sponsoring insurance company, ING USA A&L or SLD.

The ratings reflect ING USA's strong market positions in several business lines, diverse and sustainable earnings, elevated brand name recognition and judicious risk management. Additionally, ING USA's prudent asset/liability management strategies ensure that close matches between funding agreement assets and liabilities are maintained. Finally, A.M. Best recognizes the strategic benefits of recent divestitures of non-core operations, which will sharpen the group's strategic focus, improve its long-term operating performance, reduce future earnings volatility and refine its overall business profile in the U.S. asset accumulation and asset protection marketplace.

For a complete listing of ING USA's issuances under its FABS programs, please visit http://www.ambest.com/press/111605ingusa.pdf.

For Best's Debt Ratings, all other Best's Ratings, an overview of the rating process and rating methodologies, please visit www.ambest.com/ratings.

A.M. Best Co., established in 1899, is the world's oldest and most authoritative insurance rating and information source. For more information, visit A.M. Best's Web site at www.ambest.com.