Federal Deposit
Insurance Corporation

March 13, 2006

MEMORANDUM TO: Public Comment File

SUBJECT: Federal Deposit Insurance Large-Bank Deposit Insurance Determination Modernizaton Proposal

ING Bank, fsb (“ING DIRECT”), has reviewed the FDIC’s Proposal to Modernize Large-Bank Deposit Insurance Determinations and the Advanced Notice of Proposed Rulemaking and hereby submits the following comments. ING DIRECT supports the FDIC in its efforts to require the largest insured depository institutions to modify their deposit systems to allow the FDIC to calculate deposit insurance coverage quickly in the event of a failure of one of these institutions. It is ING DIRECT’s opinion that the insured institutions derive significant benefit in the form of increased consumer confidence from FDIC insurance and that the institutions’ should be able to quickly provide insurance information to the FDIC in the event of a failure.

ING DIRECT notes, however, that the FDIC proposal can’t be implemented and maintained without some burden, especially at those institutions with more complex business models and product offerings. For its part, ING DIRECT enjoys modern systems and a simple product line relative to some of the other institutions, making any eventual implementation of the FDIC proposal relatively straight forward. However, even at an institution such as ING DIRECT, technical resources are in high demand and there will be both actual and opportunity costs to divert resources to the implementation of the proposed modernization. Additionally, the burdens imposed by the FDIC proposal will grow as ING DIRECT’s systems and product offerings grow, adding both ongoing maintenance and testing overhead. The FDIC modernization proposal could also add significant cost and complexity to future efforts by financial institutions to acquire other institutions or portfolios.

Of the three options proposed by the FDIC, ING DIRECT believes that the first option is the most advantageous to both financial institutions and the public. We believe that the first option will provide the fastest and most accurate mechanism for the institutions and the FDIC to work together through the insurance determination process. ING DIRECT believes that the second option, which requires only a subset of the data required by the first option, is essentially equivalent to Option 1.

ING DIRECT expresses a strong preference away from Option 3. ING DIRECT believes that the FDIC, and not the financial institution, should make insurance determinations. ING DIRECT also believes that applying this rule to only the very largest of the covered institutions adds unnecessary complexity, as the membership in this group will change over time.

Regardless of which option is chosen, ING DIRECT would prefer that all testing of ING DIRECT’s information be done solely on our site in order to minimize the amount of customer data leaving our premises. ING DIRECT also believes that the use of industry standard strong encryption routines should be required for any transmission of data between our institution and the FDIC.