ING Groep NV (ING) 2006 Q3 法說會逐字稿

Welcome to the ING Q3 results conference call on the 9th of November, 2006. Throughout today's recorded presentation, all participants will be in a listen-only mode. After the presentation there will be an opportunity to ask questions. (OPERATOR INSTRUCTIONS)

I'd like to turn the conference over to Mr. [J.C. Ray]. Please go ahead, sir.

Good afternoon. This is J.C. Ray for ING Groep welcoming you to ING's third-quarter 2006 results conference call. Before turning this over to Cees Maas, Vice Chairman of the Executive Board and CFO for ING Groep and Tom McInerney, member of the Executive Board responsible for Insurance Americas, let me first say that any forward-looking statement in today's comments are subject to a number of variables including interest rates, foreign exchange rates, inflation rates, movements in the securities markets including [annuity] markets and underlying economic health and changes. Realization of forward-looking statements could be materially altered by unexpected movements in any or all of these and other variables.

That said, good afternoon Cees. Good afternoon, Tom. Cees, over to you.

Thank you, J.C. Ladies and gentlemen also on behalf of Tom McInerney, Executive Board and Jonathan Atack, our General Manager of Investor Relations who is present here as well. Good morning, good afternoon wherever you are in the world welcome to this conference call.

I would like to give a very brief introduction and then we are open to answer all the questions you have. As we said in our press release ING posted solid third-quarter results in an environment, in an interest rate environment that was challenging for us for all of us. Underlying net profits declined by 3.2% and that decline was mainly caused by EUR196 million negative variation from revaluation derivatives to which hedge accounting is not applied, roughly EUR110 million in the banking side and roughly EUR90 million in the insurance side. Net profit decreased by 16% and that includes then compared to underlying profit loss on the sale of Deutsche Hypothekenbank and the release of the tech provision in the third quarter of 2005.

Our performance year-to-date, so that means for the first nine months, was strong underlying net profit going up by about 20%. Value creation, as you know ING is focusing on value creation. It continues to be strong.

In the first quarter we continue to grow in markets where we can achieve attractive returns. The discipline has resulted in strong first nine-month returns, risk adjusted returns. Economic capital on the banking side was slightly up to 20.5% after-tax, very decent return. And internal rate of return to new life sales increased by 13.8% from 12.8 and that was driven by developing markets where margins were higher.

The value for new business in the third quarter was now EUR122 million which was 60% of the total of the value of new business for ING life insurance business. The growth engines as you know we have them. ING Direct to life insurance in developing markets and retirement services they did well. ING Direct focus this quarter in particular on mortgage growth driven by the challenging interest rate environment, a flat yield curve, in fact an inverse yield curve in the United States and a rather flat yield curve in Europe.

There was a record increase of 5.8 billion new mortgages in the third quarter compared to a 3.3 billion increase at funds entrusted on the savings side. Life insurance in developing markets, sales were up 13% and I referred already to the value for new business which increased by 22% in the developing markets. And the retirement services, yes, the sales declined in the third quarter due to the lumpy volatile nature of the business. We had no large single cases sold in the third quarter. But on the nine-month basis, the value for new business was up 33% this year in retirement services.

We continue to invest in growth of the business over the longer term. We continue to take initiatives. We refer to allowance of ING Direct in Chicago, in the city of Chicago in September. We have introduced as we have announced before mortgages in the United Kingdom. We are preparing to apply for a license to start a life insurance greenfield in Russia. As we said before we have a team on the ground to see whether we can start ING Direct in Japan. So we will continue to invest in future growth.

Finally, cost is under control. The cost (indiscernible) in the bank in the third quarter increased slightly but it improved on a nine-month basis to 62.8% for the bank. The efficiency ratio for insurance improved also supported by in part the release of the provision for employee benefits and pensions in the Netherlands. That cost is seriously under control.

Looking forward, finally, low long-term interest rates and flat yield curves will continue at least in the short period, in the near future ahead of us and it will pose challenges. Nevertheless and however, we benefit from strong equity in real estate markets as well as from favorable claim experience in our normalized operations.

On balance, ING is well positioned to capture growth opportunities and we are confident in our ability to create value for our shareholders.

With this introduction, I would like to open the floor for your questions. Thank you.

(OPERATOR INSTRUCTIONS) Mark Cathcart.

Mark Cathcart from Deutsche Bank. First question is in relation to Japan where I think for the second time we've had increasing lapse assumptions for COLI. I just wondered why is it that we've had to have a second round of lapse assumptions for COLI and may we get a third?

And second question is ING Direct, am I right in thinking that on the deposit side you are still making more margin than you thank you are going to make over the longer term? I think you are making or intend to make about 80 to 85 bps but you are currently making higher than that. So therefore should we expect structurally lower margins going forward?

And in relation to ING Direct, is the marketing cost the mortgages likely to go up quite noticeably next year specifically in relation to the UK?

Hello, Mark. Thanks for your questions. As far as the marketing cost of mortgages is concerned, yes, you know they are higher for mortgages than for savings. That is why indeed the increase in the profit of ING Direct -- increase in the profit in ING Direct's slowdown compared to the third quarter last year.

Yes, marketing costs in the UK will go up because of the mortgages. That is correct. We have already spent a lot of marketing in the UK. We launched in October as you know and you can -- we had by the way we had in the third quarter last year we had a loss in the UK of EUR6 million, now we have a profit of EUR3 million. So it is -- UK is profitable. But yes it will certainly impact the increase I say increase in profits in the United Kingdom.

Nevertheless we feel that it is highly value creation the mortgages. It is important for us to have it also from a diversification point of view and from a currency point of view to have it and it creates value over the longer term.

On the deposit side, I don't expect a further structural decrease in margins in the deposit side. Of course it very much depends on the fact to a large extent, it depends on the shape of the yield curve and on the move of the yield curve. If it stays where it is then you might then there is no reason to believe that the margin will go down.

In relation to that answer, Cees, in the space, I think you increased your deposit rate last quarter by 5 bps and in a number of European countries by say 20 bps. How much of each of those rises was due to short-term rates going up and how much was due to for instance in the States to competitive pressures getting greater?

We increased our rates in the third quarter because the interest rate in the second quarter went up. And we increased most of our rates early in the third quarter and correctly so. Of course you increase your rates partly or largely, whatever you want, because of competition. If there is no competition and you have a flat yield curve then you are inclined of course to slow down the increase a little bit in order to keep up your profitability. Everyone will understand it in a flat yield curve environment.

In particular in the United States, the increase was driven by competition. That is to say we are lower in the United States with our rates than our competition is. So, yes, it is. However, this is how it is. Therefore we focused more on mortgages also in the United States. If I look at the increase in mortgages in the U.S., the funds entrusted in the U.S. went up by -- in fact stays flat in local currency and the mortgages went up by roughly 1 billion.

If rates or the yield curve stays where it is today, do you think there is any risk that you may have to increase your deposit rate in the States or any other country further?

Yes, certainly so. We have done so already.

If yield curve stays where it is and rates stay where they are, do you think you may have to up your deposit rate to remain competitive?

No. Then there is not let me think if there is a country where there should be a reason to increase rates? I don't think so. We have increased the rates in Spain in October by 20 basis points and in Germany by 10 basis points. I don't think there is a compelling reason (multiple speakers).

So you don't see any reason or any chance if you happen to increase your rates further in the States due to competitive pressures aside from movements in rates?

Well your formula is almost like a lawyer, Mark, because if you ask me if I see any chance of increasing rates, that depends on what my competitor is doing over the remaining part of this quarter. But my competitor has at least the same issue that I have. And in the United States, we basically have only two main competitors and that Citi and HSBC. And as you know Citi mainly does it for defensive reasons and HSBC has an offensive strategy. So, yes, there might be a reason to do so. But I don't feel -- I don't think that it is likely that they face the same challenge that we face in the U.S.

Thanks.

On Japan on the lapses, let me check where -- as you know the lapse assumptions were updated. We have been changing in the tax regime, as you know as a consequence of which the COLI products come to an end, to a natural end in terms of the time that is attractive for the client to lapse was earlier because of the change in the tax rate then we had originally assumed. You do that at the moment the tax rate than we had originally assumes. You do that at the moment that the tax regime is changing and then you track whether your assumptions or lapses are correct or not. Apparently there were more lapses than originally assumed. So yes, we might update it again in Q4 and update but it's just on the basis of experience.

Okay, thank you very much, Cees.

Nick Holmes.

Nick Holmes at Lehman. I had three questions. First one is can you update us on the loan loss releases coming through in the wholesale bank? You say you expect potential releases to reduce over the coming quarters. I wonder can you help us to quantify this in some way by for example telling us the size of releases in past quarters?

Secondly, I wondered if you could take us through in a bit more detail what is happening to your bank interest margin particularly in Holland? And as a related question how does the margin of your new budget mortgage product in Holland compare with your other mortgage products?

And then third and final question is on the XXX reserve requirements in the States which caused your margin to fall a bit there, I wondered if you could explain what is going on? I think you've replaced -- you hadn't replaced your letters of credit yet. I wonder if you could explain a bit more? Thank you very much.

Nick, thank you. First of all the loan loss releases. I don't know if you have seen our analyst presentation on the website on slide 17. It is an interesting bar chart because what it shows is the gross additions in combination with the releases. And the message is here that as from 2002 onwards the releases are in effect quite stable around say 25 basis points. In 2002 it was the releases there were 21; in 2003, there were 31; in 2004, 23; in 2005, 29; in the first quarter of this year, 25; in the second quarter, 30; and only in the third quarter, it was for the first time historically low at 16.

That is an interesting thing how stable the releases are. And it has an explanation because releases are done on the basis of the work of or shall I say the intensive care unit that we have. If a loan loss is past due, then it goes to another department and they are trying to work out and recuperate as much as they can. So this is sort of the flow of work that is coming out of this unit. And therefore there is a certain stability.

But you understand then that the most interesting thing if you look at this is what the gross additions to loan loss provisions were and there you see that since 2001 there is a gradual reduction of it and it stabilizes in 2006 -- 24, 22, 29, 21 basis points, addition gross additions to the loan losses. But in combination with the third quarter releases of only 16 you see that for the first time an increase; the quality of the loan portfolio remains the same.

As far as the releases looking forward is concerned, while I can only say that probably they will stay on the relatively low level because we hardly have added anything. But you never know. What we see this is new today that -- not new today but it's a phenomenon that is here over the last year or two that sometimes you have releases because companies in trouble are taken over by private equity firms, the loan losses -- the loans are being restructured and you release provisions which has nothing to do with the restructuring of your own intensive care or workout unit that has been triggered by the market as what we didn't see in the past.

So sometimes there is nowadays you see from time to time that releases are being triggered by events in the market and not so much by ourselves. So that makes it a little bit unpredictable of the loan loss releases going to forward will be. But they will certainly be lower than the average that you've seen say since 2002 as we have seen on slide 17. But again, it can not be excluded -- there will be volatility because as I said of this behavior of the private equity funds. That is the best I can say.

That is very helpful indeed. So the message is that we should be looking at the average so the 16 bps in Q3 is looking reasonably low you would say against an average?

Yes, certainly so. Certainly so, absolutely. Look at the slide and you will see it yourself. The conclusion is easy to draw.

Then your question on the mortgage. What is the margin on this new mortgage? First of all I don't tell you of course for commercial and competitive reasons. But the message was that we gave you is that we this new mortgage production in particular in the bank was -- mortgage has all sort of embedded options. One of the embedded options is that in the Netherlands and almost every mortgage has that that if you ask for an offer for a mortgage then the offer runs for two to three months. And in that offering period if the interest goes down, you get the lower interest on your mortgage. If the mortgage goes up, you stick to the originally offered interest rate.

We hedge that option of course in the market so there is a flow of production and we know the flow of offerings in production and we hedge them in the market. What we offer now to the client is to delete the option that if the interest rate goes down that it gets lower option. And as a consequence of which we could reprice our total interest rate for the mortgage by 20 basis points lower; that's the price of hedging and hedging the option.

The clients love it because there is a general feeling in the market that the interest rate can only go up. So if he compares them in a mortgage offering by a competitor where that option is embedded and it is a 20 basis point higher interest rate for the total tenure of the mortgage, then he prefers of course to delete that option and choose for the 20 basis points lower.

So it is good for the client. It does not impact our margin on that mortgage and so it is a win-win situation. The only one who loses is probably the ones who are trading in derivatives who don't make the costs there.

Okay, that is very clear.

And then the XXX? --

I also just wondered if may be could take us through in a bit more detail just the overall bank interest margin development in Q3 in Holland in particular?

Yes. Overall interest margin booked to 106 -- or increased, sorry -- increased compared to Q2 from 100 to 106 basis points as compared to Q3 '05 then it dropped from 122 basis points to 106 basis points. I think we have explained to you. I don't know when but last time somewhere that about the compared Q3, Q3 so 120 basis on 106. That was for 12 basis points at least caused by a reclassification between trading income and interest income in Belgium. And in the first quarter for 3 basis points in the Netherlands. So we did this same.

In the third quarter it was impacted and I speak about the banking interest margin as a whole. We had a decrease of sorry -- an impact of the DHB for 4 basis points. So the DHB has a very small and very narrow interest margin. So the interest margin in effect underlying in the second quarter it goes down from 103 to 102 if I correct for everything; Q2, Q3, actual going up 100 to 106 corrected for reclassification in Q2 and for the DHB margin in Q3, there's a 1 basis point deterioration in the interest margin for the bank as a whole.

1 basis point deterioration?

Yes, in the third quarter compared to the second.

Thank you.

In terms of the XXX and A-XXX reserves we've always been required to hold additional regulatory capital beyond economic capital. Last year the state regulators actually increased the amount of regulatory capital requirements. We had in the past solved that issue through reinsurance and LLCs through our offshore captive, but in April of 2006, the IRS changed some of the tax rules. So that we found it more capital and tax efficient to set up onshore captives versus offshore captives.

So we're in the process of setting those up. We're going through the final regulatory review and approval and we would hope to have those onshore captives up and running so we would run our reinsurance through them either in the fourth quarter of '06 or first quarter of '07. And then we will recover the value of new business when we have those captives set up. So it should occur over the next couple of quarters.

Just out of interest, Tom, why is this slight time lag between The LLCs running off and your setting up your new captives?

Nick, it's not that. It's the going from offshore captives to onshore captives. You have to get approval in the states in this case two states where we are setting up the captive and then our stated domicile. So the delay from April to now is really going through the state regulatory process.

Okay, great. Thank you very much.

(OPERATOR INSTRUCTIONS) Christopher Hitchings.

Chris Hitchings from KBW. I'd just like to look a little bit at third-quarter sales trends in the U.S. because they seemed to be a bit down which I wasn't expecting perhaps I should have been. Could you tell us a little bit more about the products and what has happened and are there any aspects that were exceptional?

I think, Christopher, first of all in our retirement services business, we actually have had a good nine months with sales up 29%. I've said in the past that we think the industry can grow 10 to 15 so we are very pleased growing at and in effect double the high end of that normal range. I've also said in past calls that while we have a core business in the 401(k) market, in the education market we also have healthcare, a higher add in government business and in those businesses we tend to get some large cases from time to time.

So in comparing the third quarter of '06 to the third quarter of '05, we had a large case in '05 that was brought in 610 million and if you back that out of the third quarter of '05 then the quarter-over-quarter would have been up 360 million, third quarter '06 versus third quarter of '05 and that would have been up about 27%. So we actually think the core run rate of our retirement service business is quite strong and quite strong compared to our competitors.

On the annuity side, again, we are up about 8%. We've just introduced a new withdrawal benefit in our life based series so I think that is going well. On the life side, in universal life, that is down and that is down because our guaranteed premium UL and our accumulator UL are not competitive enough. We have restructured the product and relaunched that recently on the UL side.

We are doing very well on the term side. Term applications that are placed -- sold are moving up quite nicely. We think we're getting to a 50,000 run rate level. So we are quite pleased there. And we've introduced two new term products recently.

so I think universal life will be down. We have decided unlike some of our competitors not to offer nonrecourse premium financing ULs and those tend to be big policies so that in part also explains the UL decrease. So overall our two big businesses, retirement services and annuities which produce 80% or more of the value of new business are doing quite well, growing, nice IRRs, good value of new business. And the life business is a challenge. Pleased with the term momentum and we need to I think to see how we do with these new products on the UL side.

In terms of large cases can you update us at all on what the pipeline is for Q4?

Well, we do have one case -- it's not as large as last year's but it is a significant case. So we -- that's in the pipeline and we are also seeing pretty good momentum in the core 401(k) and education business.

Thanks much.

Duncan Russell.

Duncan Russell from Fox-Pitt, Kelton. Just a quick question. It was on the front page of your press release, you say that looking forward the low interest rates and flat yield curves will continue to pose challenges. Obviously that is to be expected. I just wanted to get an understanding of whether you are saying that if the yield curve and interest rates remain where they are, you will continue to see margin pressure and sales pressure? Or whether -- I don't know exactly what you are trying to say. Are you warning or are you just saying that it has been hard and it is going to remain hard? Thanks.

Yes, the latter one more than the first one. If the yield curve stays where it is then it goes around in the third quarter and it is hard in the [first] quarter is what we said. However, if I look at the explanation that we gave -- but the explanation that we gave on the swing of 169 -- EUR196 million on the derivatives that was caused by a plus 111 in the third quarter 2005. Now -85 in this quarter if the interest rate don't change anymore, if it stays where it is and so far there is no change in the interest rate environment neither in the U.S. nor in here -- only a few basis points short-term up but long-term stays flat. Then there is zero impact on these derivatives and that means automatically a swing of plus 85 from minus 85 to zero on this fact.

There is no guarantee. It's only 9th of November but again on the assumption or your assumption that interest rates stay where they are that at least helps in this component that is not tough that is good news of course. But in the ING Direct environment, I answered already Mark's answer that I don't expect major shift than -- or important ones or maybe not any in the credited rate for ING Direct. But the yield curve is flat, as we do know. So we will continue to focus on mortgages in those cases.

And in the ALCO book on the insurance side, yes, the carry as we call it, so the interest rate that you make up the difference between long and shorter rates, yes, that is low if not absent. So this continues to pressure on a lot more in the third quarter but on the total results.

The same applys to the low interest rate environment on the insurance side. But at the same time if the interest rate does not to go down further one might expect for example the negative bond impairments might go down. So if there is no change then relatively speaking it is good news. I would love to see the steeper yield curves around the world. But I don't know if (multiple speakers).

Have you taken all the pain from the flattening of the yield curve year-to-date or is there like any lag? Have you taken most of the pain so far? So are these kind of cyclically low earnings or is there more pain?

That is a good point. I don't think, as I say, I don't think that if the yield curves stay here that we will be faced with additional pain because that is what your question is. I don't expect that.

Okay, thanks.

(OPERATOR INSTRUCTIONS) Mark Cathcart.

The question was in relation to Taiwan. I just wondered if you could remind us what the sensitivity is for a 10 bp move in interest rates on your reserve, where your reserve currently is and what interest rate level the reserve is based on? Please.

Yes Mark. Very simple, no change. A 10 basis point drop in interest rate decreases leads to a decrease of 150 million of reserves without any change in assumptions of course because in the third quarter, we have this change in mortality assumptions based on experience of the products. And that helped us a little bit otherwise it would have been closer to zero than it is today. But without any change in experience 10 basis points is 150 million plus and negative.

And so what is the reserve at the moment and what interest rate is it based on?

At quarter end it was -- the rate was 231, if I remember correctly -- sorry -- 225. And today and I have someone who looks at it every day, 218, 219. So it is 6 basis points lower. That is 90 million, Mark.

Sorry. So at the moment it is 2.1 or whatever the interest rate but what interest rate is your current reserve based on and what is your current reserve?

The current reserve is 253 million.

Based on an interest rate of --?

225.

Thanks.

But Mark, the interesting thing of Taiwan is this is based on liabilities that run up to 40 years. To be honest, this is important to report on that on every quarter and also to be honest with myself, I look at it on a daily basis too. It's is affected it is ridiculous what we are doing. This is based on assumptions where daily rates and forward rates because we wholeheartedly apply the European embedded value principles where we say that if there is a forward rate and we apply the forward rate. But the forward rate is not different in Taiwan from the spot rate. So the forward rate is also around that level of 220.

And we look at it every day for a forty-year liability. This is our life. I don't blame anyone. But we should avoid really looking at it -- this on a daily basis because it this does not really make sense. But you do it and to be very honest with you I do it also.

I don't do it. That's why I had to ask you the question. Can I ask another question on Asian growth if possible?

Yes, please.

Korea obviously fell and has recovered a bit but there are regulatory changes earlier in the year. You sacked your CEO in Taiwan so therefore things picked up a bit. Japan, you've got these tax changes that led to lapse surrenders being higher than you anticipated. It's all been a bit all over the place. So are we now entering a period of reasonable stability, an upward path in growth in those three core territories on a going-forward basis? Or is there something you might be able to indicate to us that might lead to a further disappointment?

Is it all clean sailing from here or is there anything that you know that might disappoint on a going-forward basis? I think in Japan you were releasing SPVA product dollar denominated. I don't know if you are excited about that or not excited. I just wondered if you could tell us what your expectations were for Asian stability and growth?

Well, I think this is a good point. First of all Taiwan, I don't know exactly what the wording was that you used but the CEO has left after 42 years --.

I thought you missed product in the second quarter last year. But anyway, he left. So you've got a new CEO who is really, really invigorating things (multiple speakers).

-- no reason to ask someone to leave of course. But he has left so you cannot leave twice. And Taiwan is doing pretty well. Let's be honest. We disclosed that we had added to the reserves 75 million in one quarter. So if we would have recognized the profit, which we don't, then we had a 75 million profit in one quarter which is pretty good. So the underlying business is doing very well in Taiwan and I don't see a real reason for change there. That is my first remark.

My second, the value from the business by the way was 37 million which was up 42% improved profit margins and expense under runs so no consumption changes so to speak. So internally, yes, good internal rate of return up to even 19.4 up from 13.4. I see no reason to change that other than -- and now I come to the others like Korea or Japan. Yes, up until recently ING and Hartford were mainly the dominant players in the SPVA market. And this is like ING Direct, if you finally believe that it's a good product then you encourage the competition to come in which happened in the Japanese market. It's okay, it's fine. I mean you can't expect that you make high margins, high profit being alone in the market all the time, that the way it is. So that's what happened.

The same and I spoke to that before if we make high margins, high profit in certain areas then you have two things that always happen. First competition comes in. I just said described that. And second, in my -- in particular in insurance you might expect regulatory intervention. That is what happened in Korea. They introduced the regulator in mortality tables and we had to figure in the mortality tables, fine, fine for us. It is a sole industry issue. So that is why value of the funeral business went down. That is how it is.

Do I expect more? I think we make decent profit there. We still have a very strong market position in Korea and that is it. I don't see it as a general increase in volatility and of course what you asked me in particular the negative side in Asia.

So there is no regulatory issue or competitive issue which we haven't yet learned about which you may know about?

If I had known, then I would have disclosed it. That's how I am. You know me.

Thanks.

Nick Byrne.

Nick Byrne of JPMorgan. I just had a quick follow question actually on Taiwan. Rather than thinking about the current reserve adequacy, I wondered whether at some point in the future perhaps at the year end you would be considering changing the long-term swap rate assumption which if I remember was 5.75%. As interest rates have moved lower do think it is now correct to actually adjust that? And if so, can you give some sensitivity as to how the reserved efficiency change as that number changes?

Of course. This is the question that we went into at length last year in the [Lehman] investor relations conference. We have now, as you know, fully endorsed as one of the few by the way insurance companies, the European embedded value principal and the market consistent embedded value so that means if there are market rates you apply the market rates and if there are no market rates, you try to be as consistent as possible with the rest of your assumptions. So that means for the next 20 years we use the market consistent forward-looking rate which is still around that level of 2.2, 2.3. And after that the original rate.

It amazes me there was a rate anyhow for 20 years in Taiwan, but there is one. And then we gradually go up to a consistent rate and we feel the only consistent rate that we have is that the long-term rate in the country equals the expected inflation rate was the long-term growth capacity -- a rate of the growth capacity. If long-term rates are 2% which is extremely low for an Asian country, and the long-term growth capacity of 375 which is extremely low for an Asian country and also historically, then you come to 575.

If we would go for the 2.2 forever, I think that to the lower (inaudible) by 1.5 billion that is what I have roughly speaking. Yes if we go to the full -- if you extend the forward curve so to speak on top of my head because I don't have the numbers with me. We gave that to you last time, but roughly speaking that is the number.

Thank you.

(OPERATOR INSTRUCTIONS) Sir, there are no further questions at this time. Please continue with any other points you wish to raise.

Okay, if there are no further questions then I would like to thank you very much for all of you who have attended this conference call but also and in particular for those who asked the questions, we very much appreciate it. Hope to see you next time. Thank you very much also on behalf of Tom and Jonathan. Thank you.

Ladies and gentlemen, this concludes the ING Q3 results conference call. Thank you for participating. You may now disconnect.