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ING Capital Markets LLC (INGCM) is a Delaware limited liability company and a wholly-owned indirect subsidiary of ING Bank N.V. INGCM is registered with the Commodity Futures Trading Commission as a full service swaps dealer. INGCM acts as a counterparty to its Domestic and International client base in a broad variety of product offerings including but not limited to FX, Rate, Equity, Commodity, Credit Default and Inflation Derivatives. For further information, please contact one of our product representatives for a solution that is right for your needs.

Michael DwyerRegional Head of Sales+1(646) 424-6117
Wei-Tong ShuHead of Rates Trading+1(646) 424-6113
Bruce HarrisHead of Credit Trading+1(646) 424-6080
Chika OkamotoHead of FX Sales+1(646) 424-6118
Katleen Van GheelHead of Equity Derivative Sales+1(646) 424-6671

Or you can e-mail us at ING Capital Markets (ingcm@americas.ing.com)


Disclosures
INGCM is providing to its counterparties on this website certain standardized swap disclosures which are required under the External Business Conduct rules of the Dodd-Frank Act. You should review these disclosures as well as any information set forth in the links provided herein. (Please see above right, “Disclosure Links”). In addition to the disclosures contained on this website, you should read carefully any additional disclosures contained in any documentation provided to you from time to time by your INGCM sales representative.

By transacting with INGCM you are deemed to acknowledge that you have read and accepted the information provided on this website. The information will be updated from time to time so you are urged to revisit this website periodically to make sure you have the most current information available.

Pre-Trade Disclosures
Prior to entering into any swaps with a Non-Swap Entity, we will communicate to you what we believe to be the material economic terms of the swap as well as the pre-trade mid-market mark. You should also refer to any documentation that INGCM has sent to you or that we have previously executed, including, but not limited to, any master agreement, master confirmation agreement, confirmation (including any confirmation relating to a prior swap), term sheet or other summary of economic terms. Please communicate with your INGCM representative if you believe that any material economic terms of a swap have not been provided to you.

Documentation provided to you by INGCM may reference certain other documents and definitions, including those published by ISDA. Any such referenced documents or definitions (including those found at the “ISDA Bookstore” (http://www.isda.org/publications/pubguide.aspx) are available from your INGCM representative upon request. For your convenience we have included on this website some standard ING swap templates.

Additional information, including standard product terms, other confirmation templates and market conventions for various asset classes may be found in the Material Economic Terms “Disclosure Link” on the above right.

By entering into a swap with INGCM you will be deemed to have acknowledged that you have received from INGCM prior to entry into such swap the relevant disclosures, notifications and other information sufficient for you to evaluate the material risks and characteristics of such swap.

Upon request, a Scenario Analysis is available to each Non-Swap Entity counterparty. Such Scenario Analysis may include a rage of assumptions, including downside stress scenarios. If you wish to obtain such Scenario Analysis please contact your ING Capital Markets representative.


Recording of Conversations
ING Capital Markets LLC (INGCM) may record telephone conversations between or among INGCM personnel and third parties. These recordings may be used for regulatory purposes or be submitted in evidence in any proceedings.


Suitability Disclosure
Generally speaking INGCM does not make recommendations to clients as it relates to derivative transactions. ING Capital Markets is acting in its capacity as a counterparty and is not undertaking to assess the suitability of the swap or trading strategy involving a swap for the counterparty.


Clearing Disclosure
For counterparties who are not Swap Dealers, Major Swap Participants, security-based swap dealers or major security-based swap participants you are entitled to the following rights:
  • (a) in connection with each swap that is subject to mandatory clearing, you have the sole right to select the derivatives clearing organization through which the transaction will clear; and
  • (b) in connection with each swap not subject to mandatory clearing, you have the right to require clearing of the swap and select the derivatives clearing organization through which the transaction will clear.

Complaints
Complaints should be directed to the Deputy Director of Compliance John Espin.
By Phone: 646-424-8116
By E-mail: John.Espin@Americas.ING.com
Alternatively, you can write to us at the address below.

ING Capital Markets LLC
1325 Avenue of the Americas
New York, NY 10019
U.S.A.

Disclaimer:
ING Bank does not have a commercial banking license in the U.S. and therefore is not permitted to conduct a commercial banking business in the U.S.. Through its wholly owned subsidiary ING Financial Holdings Corporation, and its affiliates, it offers a full array of wholesale products such as commercial lending, corporate finance and a full range of FM products and services.

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