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Operator
Good morning. This is Sala welcoming you to ING's 4Q 2010 conference call.
Before handing this conference call over to Jan Hommen, Chief Executive Officer of ING Group; Patrick Flynn, Chief Financial Officer; and Koos Timmermans, Chief Risk Officer; let me first say that any forward-looking statements in today's comments are subject to a number of current views, assumptions, and variables, including interest rates, foreign exchange rates, inflation rates, movement in security markets, including equity markets, and underlying economic conditions and changes. These are set out in greater detail in our public filings, which we would urge you to read.
The realization of forward-looking statements could be materially altered by unexpected movements in, on, any or all of these other variables.
Good morning, Jan, Patrick, and Koos. Jan, over to you.
Jan Hommen - Chief Executive Officer
Thank you very much. Welcome, everyone, to the fourth quarter ING result conference call.
I'm happy to report that ING is continuing to make good progress as we prepare the Bank and the Insurance companies for their future as standalone companies. The Bank posted another strong quarter, and the Insurance Company is showing a solid improvement in operating profit, although on an underlying basis, results were impacted by the measures we announced last quarter to address the US Closed book Variable Annuity block.
The good news is that markets improved in Q4, and the total impact of the VA measures we announced last quarter was lower than we originally anticipated.
I will talk you through the presentation now; and afterwards, Koos Timmermans, Patrick Flynn, and Matt Rider, our CFO of the Insurance Company, are here with me, and we are all able to answer your questions.
Let me go to slide 2. ING Group reported an underlying net profit of EUR644 million. That was up from EUR90 million a year ago.
The Bank had another strong quarter; an underlying profit of EUR1.5 billion before tax.
Operating result in Insurance increased to EUR438 million, compared to EUR303 million in the fourth quarter last year. Underlying result impacted by the announcement we made already last quarter on the DAC write-down; that had an impact of EUR975 million before tax.
Operational separation of the Bank and the Insurance was complete, and the two companies are now operating arms length as of January 1 this year. The separation now enters phase number 2, as we are now working to legal and operational separation within the Insurance organization.
And the focus for 2011 will be to prepare the Insurance Company for two IPOs; and at the same time, that we want to work towards the repurchase of the remaining outstanding core Tier 1 securities from the Dutch State.
On slide 3, you can see that the Bank had another strong quarter, and certainly compared to Q4 last year, and almost on par with the third quarter.
Insurance Company operating profit improved significantly from a year ago, mainly because of investment spreads as cash balances were reinvested.
Underlying result, as I mentioned earlier, impacted by the DAC write-down on the US Closed book -- Closed Block. For the Group, that had an impact that the underlying net profit was EUR644 million. Compared with Q4, that was significantly up last year, but down compared to the third quarter this year, and that was due entirely to the DAC write-down.
Net profit, EUR433 million. We had special items impacting on that of about EUR229 million, primarily as a result of the separation process we are in and some restructuring programs.
Page 4, you see the full-year results, and you can see that the Bank really had a good year. In fact, earnings are now up to levels that were pre-crisis.
Insurance, operating profit improved in 2010, and underlying result for the Group was EUR3.9 billion, up fourfold compared to last year, with a net profit of EUR3.2 billion compared to a loss of EUR935 million.
On slide 5, you see that we, compared with the ambition we issued last year, are making good progress. Strong income generation by the Bank. Healthy margins, and lower market impacts really had a significant impact on our numbers. And excluding market impacts, income rose by 7.4%.
Cost-to-income ratio stable at 54.2%. If we exclude the impact of markets, risk costs are trending towards the more normalized levels.
Return on equity, if we calculate that based on the 7.5% core Tier 1, we assumed when we made our plan for the ambition 2013 of 17.6%, and if we calculate that based on IFRS equity, then the return is 13.1%.
The same for Insurance; good progress on the ambition; healthy growth in the general account. Investment margins were up to 93 basis points, compared with 83 basis points. That's on a four quarter trading trend line.
Administrative expense slightly down, despite some accrual adjustments we made last year to our bonus deferral, which benefited the numbers in Q4 in 2009.
Sales growth continued to exceed our targets, which was 10%. We were up here 17.3%, but we are maintaining very strict pricing discipline. And the return on equity is still lagging our objectives, but it was mainly impacted by the DAC write-down.
When you look at our separation process in slide number 7, the operational separation is completed now as of January 1 this year, so we are working together on an arms' length basis where we share infrastructure and where we do activities together. The separation costs were EUR85 million after tax.
And the focus for the year 2011 is to make the interim solutions more permanent, mainly related to IT. We expect that we will spend this year about EUR200 million after tax in order to get us there, and that we will focus also internally within Insurance on separating the US operations from the other activities, and to make sure that we align our Investment Management activities with our two IPO structure.
We will align the Insurance structure to the new IPO. That means that we will take a look at our legal structure in the first half of 2011; and we also will be looking at getting our regulatory approval process in place so that we can do IPOs by the time that we are ready for that.
Investment Management; we'll continue to cooperate across all the regions to ensure that we have our customers really provide with continuity in terms of product distribution and investment expertise.
Looking in particular at the Bank, you see on the left side that the Commercial result of the Bank rose compared to Q4 last year, but declined somewhat compared with the third quarter, reflecting the seasonality in financial markets, also combined with some higher expenses here.
Risk costs increased slightly in Q4 after three quarters of decline. However, the market impacts also included a gain on the sale of the stake in Fubon, which was about EUR189 million, which was reported in the corporate line.
And an underlying result before tax was up strongly compared with Q4 due to lower market impacts, and almost at the same level as Q3.
The net interest margin, on slide 10, rose to 147 basis points. That is 6 basis points higher than both the third quarter of 2010 and the fourth quarter of 2009. And we expect the net interest margin to remain stable at around 140 basis points for the quarters to come.
Margins in particular benefitted from Structured Finance, where we a saw continued increase. Margins for mortgages and savings remained healthy in all businesses, where we see a little bit more competition for these -- for a number of areas, in particular, the mid-corporate and the SME market, and especially here in the Benelux; while at the same time, we see that demand for loans is still subdued in those areas.
On the right hand, you see also the results, interest results held up well. And they rose by 11.6%, mainly driven by client balances and higher interest margins.
Looking at costs on page 11. On a reported basis, the cost increase was 1.4% compared with the year ago. But if we exclude currency and a number of exceptional items, then expenses were up 9.2%.
We had some special items in here. We had a new deposit guarantee system in Belgium; and we had higher marketing expense at the end of the year in support of the brand; some special campaigns we had. And we had increased expenses for staff, also external staff, in particular related to IT projects that we are undertaking to replace old infrastructure, as well as building on new activities.
On a full-year basis, adjusted expenses are up 3.1%; and I can assure you that we will be very vigilant on cost control in the year 2011.
Risk costs continued to trend down in 2010. But in Q4, we saw a small increase; a small increase to 51 basis points on average risk-weighted assets; and it was mainly visible in the Retail Banking, driven by model changes on the mortgage portfolio. For the coming year, we see risk costs as a percent of risk-weighted assets to be slightly below the level of 2010.
The next slide, you see the non-performing loans; a slight increase to 2.2%. And the increase in risk costs was mainly driven by the model adjustments we made on the Dutch mortgage portfolio, which still has an NPL that remains stable at about 1%.
On page 14, you see the results of the retail banks. Well, retail banks had underlying result before tax increase compared to last year's fourth quarter, but had a decline basically due to higher expense and higher risk costs.
Looking at the Commercial Bank, you see here that the Commercial Bank, excluding Real Estate, had a strong increase in results compared with last year; up about 39%. And you see also that it was impacted by mainly Structured Finance doing very well, and core lending activities, compensated by lower results, which is normal seasonally in financial markets.
And good news also on our Real Estate division. That turned positive and made a contribution of EUR80 million, helped by stabilized property prices.
When you look at our Real Estate exposure, then it is coming down; a decrease from EUR3.3 billion to EUR2 billion at the end of Q4, largely explained by the sale we did in Summit in Q4.
Yesterday, you saw that we announced that we have reached an agreement to sell the majority of our Real Estate Investment Management business for $1 billion. And we have sold another $100 million of equity interest in our REIM funds. Altogether, that will be delivering a gain of approximately EUR500 million by the time that we close this transaction.
Investments in real estate development projects continued to decline. They were EUR2.3 billion in Q4 last year, and now they are EUR1.8 billion. So we continue to work on reducing our exposure in the real estate area.
Core Tier 1, up significantly to 9.6%; a strong generation of profit, of course, that contributed EUR4.4 billion; and the remainder as a result of a reduction of risk-weighted assets. Very important, because this will allow us to continue our discussions with the Dutch State on how we can at least begin with the repayment of the remaining outstandings that we have with the Dutch State.
And at the same time, I think we will continue to look at maintaining a strong capital position, in particular with respect to the upcoming regulatory changes that we expect under Basel III.
Moving to Insurance; operating result held up well in Q4, and has improved significantly compared with a year ago, mainly as a result of Investment margin and higher fees due to new sales and the growth that we had in assets under management.
Underlying result before tax, as noted before, impacted heavily by the EUR975 million write-off of our DAC accounts in the US Closed Block VA business.
Investment spreads up to 93 basis points, and if you look at it standalone in Q4, even to 97 basis points. I think our Investment Management people have really made a good contribution to our earnings here; and I believe that that is all I can say at this slide here.
Looking at the next one, slide 21, we see that operating results improved as a result of higher fees and premium based revenues. They were up by 15.2% compared with a year ago, primarily due from Asia, ING IM, and Latin America.
On the next slide are the administrative expenses. The year-on-year increase in expense is largely due to, on the one hand, the depreciation of the euro, and on the other hand the accrual adjustments we made in Q4 last year when we deferred a substantial portion of the bonus payments. So the comparison with Q4 last year is a little bit advantageous at this moment.
But at constant currencies, and excluding these adjustments, the administrative expenses were up 0.5%, so well contained.
Operating results are resilient in most businesses, as you can see on slide 23. The lower year-on-year result in the Central and Eastern Europe area can be explained by releases of provisions we made in Q4 last year, and the financial institution tax that we endured in Hungary in Q4 of this year.
And the year-on-year decline in IM is mainly as a result of the accrual adjustments that were made in Q4 of last year.
Sales continued to do strong, and they generate profitable sales as well, while we are maintaining the hurdle rates for margins and returns. As measured in APE, they were healthy this quarter by almost EUR1.2 billion; in particular, strong in the US, which were driven by Retirement Services and Individual Life sales.
Also Asia; Asia had a decline which was due to seasonality, but still the COLI sales in Japan were doing strong.
Slide 25, you see the impact of the DAC write-down on the US Closed Block. I don't think I need to explain that; that's quite explanatory by itself.
On slide 26, you see that the accounting has been brought in line with our US peers. The VA block is now reported as a separate business line, and that triggered by itself the DAC write-down of EUR975 million in Q4.
In addition, we have moved towards fair value accounting on reserves for the Guaranteed Minimum Withdrawal Benefit as of January 1. And the impact on equity related to the accounting change was significantly less than the estimate we made earlier because of markets that were moving in the right direction and interest rates that went up. So the charge now is only EUR700 million compared to an earlier indication of EUR1 billion to EUR1.3 billion.
The benefits of taking these measures are really important for us. The DAC balance has been significantly reduced, which is bringing the K-factor to less than 50%. The reserve adequacy has been strengthened. That was a substantial buffer on top of the 50% confidence level. And then also we have now hedged approximately 45% of the interest rate risk. And all of this I think will have a big impact on the volatility of earnings going forward, and will have a positive impact on our run-rate on an operating basis.
When you look at our capital position in Insurance, we continue to do, I think, very well at 255% for Insurance Solvency, and regulatory capital in the US at 432%, I think all respectable numbers.
What we did do in this quarter was we swapped EUR1.5 billion of hybrids for equity, so you see that coming back in the debt equity ratio in the Group. It lowered the interest expense for the Group going forward by about EUR200 million a year -- I'm sorry, not for the Group; it will reduce the interest expense for Insurance by EUR200 million.
Looking at the balance sheet, you can see that Insurance equity now is at EUR20 billion at January 1 this year, and that total equity of the Insurance subsidiaries is EUR31 billion on an unleveraged basis.
And that's important when if you calculate the return on equity per business line, then normally I think people will assume a leverage of about 25% to 35% if you want to make that comparable with what other peers are doing.
So let me wrap up the presentation.
Solid results for ING. A good, strong recovery on the Banking side. Good progress shown by Insurance on an operating performance. Charges taken on the US Closed Block will help to reduce volatility, and will ease the concern that the market has on our business.
And I believe that the focus for 2011 will continue to be to prepare the Insurance Company for two IPOs, and at the same time to work towards a reduction of the outstanding core Tier 1 securities with the Dutch State.
And let's now open it up for your questions.
Operator
(Operator Instructions). Spencer Horgan.
Spencer Horgan - Analyst
Two balance sheet questions, please. The first one is, if we look at the core Tier 1 ratio in the Bank, obviously, that's improved quite nicely to 9.6% in the quarter, but have you updated your view as to what the right number for that is prospectively in terms of the target capital strength of the Bank? And maybe you could just update us as to what the pro forma Basel III number might be on spot implementation.
And then the second one is, in terms of the debt for equity swap in Insurance, obviously, I understand that's effectively just shuffling debt around the Group, but could you expand a bit on why you've done that?
Thank you very much.
Jan Hommen - Chief Executive Officer
Okay. Prospectively.
Koos Timmermans - Chief Risk Officer
Yes, I think if you look at the pro forma Basel III results, that is something we will give later. Again, we will update at the end of the first quarter. It will be a little bit lower as it was -- we indicated 70 basis points before, but that all has to do with the revaluation reserve. That is the biggest driving factor behind there; because please note that revaluation reserve, if negative, would be deductable from your core Tier 1 in the future.
Somewhere that [reserve], over time I think, will disappear if we move more to IFRS 9, but overall, I would say it's a slightly lower number than the 70 basis points we have seen before.
And if you look at the core Tier 1 ratio, then what we have given is -- internally we work -- at the moment we say we want to be in line with peers and we feel comfortable if that number is above the 8% at the moment. So that is clearly what we are working on, but we have not made that number definite, and that will become more definite once the Basel III numbers are more clarified.
Spencer Horgan - Analyst
Okay, but it is fair to say, broadly, the Bank is somewhat better capitalized than it needs to be at the moment?
Koos Timmermans - Chief Risk Officer
I think -- well, we do feel comfortable with the capital position, yes.
Spencer Horgan - Analyst
Okay.
Jan Hommen - Chief Executive Officer
The debt equity swap, Matt?
Matt Rider - Member of the Management Board Insurance, CAO
Yes, maybe I'll take the debt equity swap. I think a couple of reasons for this. First of all, it basically mitigates the impact of the DAC write-off that we saw in the fourth quarter, together with the impact of moving to market value that we'll see in the first quarter, that EUR700 million number.
The other thing is that it reduces financial leverage in the Insurance companies, which is very important rating agencies, and it reduces the fixed charge coverage ratio, which is also important. And it also basically reduces the entanglements that were going to -- that we have with the overall Group.
Spencer Horgan - Analyst
Okay, thanks.
Operator
Farooq Hanif.
Farooq Hanif - Analyst
Two areas I'd like to explore. Firstly, I just want to understand your point about the run-rate in Insurance earnings. You seem to be positive about that, given the clean-up. So, firstly, with the write-off of DAC NVAs, and with this reduced K-factor, can you explain the expense line going forward?
And also the Investment margin has gone up. You've got a target of increasing it further. Can you explain how quickly you get there given the current yield curve?
And the second question area is just on the risk-weighted assets. You had a pretty big reduction which has been good for your core Tier 1 capital ratio generation. I was just wondering what further you have to do, because you seem to be talking about repaying the Dutch State this year. I was wondering what your plans were for the risk-weighted assets.
Thanks.
Jan Hommen - Chief Executive Officer
Okay. Matt, I think you take the first.
Matt Rider - Member of the Management Board Insurance, CAO
Yes, maybe I'll take the first one on the Insurance run-rate. I think you've seen some very good improvement over the course of the year. If you recall from the Investor Day last April, on the investment margin in particular, I think at that point we were sitting at something like 83 basis points; now we're up to 93 basis points, with a target of 105 basis points. So I think we're making some probably a little bit faster progress than we had anticipated on that line. So that's a good thing.
With respect to the DAC write-offs, obviously there is going to be less DAC to amortize going forward. I think we'll be able to give a little bit more description when we've reworked the financials to take into account all these changes. But I think you'll see some modest positive operating results coming through the VA business.
I think we'll leave it there.
Jan Hommen - Chief Executive Officer
Investment margin?
Matt Rider - Member of the Management Board Insurance, CAO
I picked that one up first.
Jan Hommen - Chief Executive Officer
Okay. RWA?
Koos Timmermans - Chief Risk Officer
Yes, on the RWAs, Farooq, yes, you've seen some declines. What you can see is that in fact we have now almost 90% covered with the Basel II internal model. So that means that has an implication for the RWAs.
Can we go much further there in declining it? I don't think so. What you will see over the next year is the Basel 2.5 implementation which will -- so you expect a little bit of upward effect rather than downward effect on this. We're not talking about large numbers, but in the end, I don't expect a lot of further decreases coming through this year, and in fact, you will see a slight upward effect.
Farooq Hanif - Analyst
Just on that point, the other driver is obviously growth in your balances. You seem to be saying that there are areas where there's some pretty good demand, particularly in the Commercial Bank. Do you think underlying balances are going to grow by the 4% to 5% long-term rate?
Koos Timmermans - Chief Risk Officer
If you look at the total amount, what you have seen is a decent amount of increases in our Mortgages; Commercial Banking relatively modest. Some segments, like the Structured Finance, have increased a lot; and overall, we expect that volume growth around the 5%, which is a bit in line with our long-term guidance.
Farooq Hanif - Analyst
Okay, thanks very much.
Operator
Andrew Coombs.
Andrew Coombs - Analyst
Three questions, please. Firstly, can you just elaborate on your aim to repay the majority of the remaining State capital aid this year? So what you're thinking in terms of timeframe there; how will you go about it; i.e., in one go, or multiple repayments. And also, your thoughts on the repayment premium of 50% and any ability to negotiate there.
My second question is just on the net interest margin. You -- it obviously has increased again to 147 basis points. Just your thoughts in terms of how sustainable you believe that could be, or whether it could revert back to 140 basis points, or even below during 2011.
And finally with regards to costs. Can you just please give us some idea of how much of the cost increase in the Netherlands, and also in ING Direct, refers to seasonal marketing campaigns, and probably won't recur in the first quarter of 2011?
Thank you.
Jan Hommen - Chief Executive Officer
Okay, let me take the first one related to the repayment of the Dutch State. We had made a deal originally with the Dutch State that we could repay at a discount. And once we had done that, we heard from the European Commission, or the State also heard from the European Commission, that they would not agree with that, and that it would mean that we had additional restructuring requirements because it would count as state support again.
That has given us some pause on what to do next with the repayment of the Dutch State. We are at this moment -- if you repay at this moment, then I think the only thing we can do is repay with the 50% premium.
On the other hand, we still have a court case that is still open. We have not heard anything yet what that could do. One of the issues in the court case is specifically this topic, and we need to wait what the answer will be before we can see whether we will either win or not win this case.
I have no indications at this moment when the resolution of this case will be. They still need to have hearings, oral hearings, which we felt were scheduled for sometime this year, and the anticipation was that we would get an answer this year.
But in the meantime, we still would like to pay back the Dutch Government, and we are in discussions with them how can we do this, and what amount can we afford to pay, also looking at the requirements we have under Basel III upcoming requirements. So we like to do it, but at the same time, we like to do it in a smart way.
Net interest margin, Patrick?
Patrick Flynn - Chief Financial Officer
Perhaps I'll give you a few minutes just to run through the drivers of the interest margins so you can get a sense of where it might go to, going forward.
At Jan said, it's been robust at about 140 basis points throughout the year, and the drivers behind that, the positive drivers have been we've seen some good Mortgage growth in the Netherlands; approximately EUR1.5 billion of production in the fourth quarter.
We've also seen an improvement to the margin as a number of our customers have retained mortgages and the duration has lengthened, which has enabled us to fund that extended duration at lower rates, which has been a positive.
ING Direct as well, we've seen good volume growth throughout. The margins there are stable. There was a one-time increase of approximately EUR21 million from the technical accounting change, but eliminating that, it's pretty stable.
A strong part in supporting margin is our Structured Finance business where we've seen good margins and good production, both in trade and export finance.
Financial markets; I think as we mentioned before, it's up in the fourth quarter, 2 basis points, but it's inherently a volatile number. In fact, the aggregate for financial markets, both net interest income and other income was down, which you normally see as a seasonal effect. So I wouldn't rely on the financial markets as an indicator of the future. It's inherently volatile.
SMEs volume, as Jan said, is low -- sorry, demand is low in this area, and there's some pressure on margins as a consequence.
If you talk about the Investment book, EUR144 billion, average duration is short and there could be some pressure on margins in this due to low interest rate as these are replaced.
On the other hand, on the liability side, it's been positive. In the Netherlands, we reduced rates in September, which had benefitted the interest margin. However, we're seeing some of our peers pushing rates up, so there's some emerging pressure there. Also in ING Direct in Spain and in France, there is stronger pressure on interest rates applied by competitors.
That said, if you look in the round, notwithstanding those pressure points, we have still managed to increase the interest margin to 147 basis points, and that's primarily driven by the two strong points which stand out, which are Mortgages and our Structured Finance business.
Therefore, the average we've seen for the full year of 140 basis points is a solid number, and we think we can continue at about this level in the coming quarters.
In terms of the cost increase, the seasonal impact, we did invest in marketing, just under EUR40 million in the fourth quarter. You can call that a discretionary increase. We also are investing in the business. We've invested in our -- a variety of IT related investments to improve the Internet platform, call centers and ATMs, which again are broadly about the same level of EUR40 million.
Jan Hommen - Chief Executive Officer
I think you will see us being very vigilant on costs in 2011. We have already taken a few steps, but not all the IT activities can be done in one year, despite the improvements that that could create. So we'll be very vigilant on making sure that our costs stay in line, and that we continue to work towards our objectives, which are 50% cost income ratio for the Bank, long term, and 35% for the Insurance Company.
Andrew Coombs - Analyst
Thank you very much.
Operator
Johnny Vo.
Johnny Vo - Analyst
Just again on the cost side as well; you're targeting this cost income of 50%. Clearly, you're saying that the net interest margin is probably higher than is sustainable at the moment. Just in terms of the costs then, are we going to see a step change in the costs? Obviously, the Belgian increase in costs there in terms of the deposit scheme is going to cost you more. So how are you going to get possibly to the 50% cost income ratio?
That's question number one.
Number two is just on the risk costs of 51 bps. You're saying that going forward, it's going to be lower than that. Is that a function of the risk-weighted assets moving up, or actually the absolute level of risk costs going down?
Thanks.
Patrick Flynn - Chief Financial Officer
On costs, if you look at -- there was an increase in the fourth quarter, but if you look at the cost income ratio for the full year, excluding market effects, it's 54%. So it's flat, and the target is 2013, so we are maintaining our drive to get that 54% down to 50% in that time period.
Johnny Vo - Analyst
Okay.
Koos Timmermans - Chief Risk Officer
Yes. And with regards to the risk costs, mathematically you are right that you have both the effects. I think overall what we expect is that the risk cost level will -- that the overall amount of risk cost will go down slightly. I think in fact if you look at the uptick which we had in Q4, a number of them were one-off calculations of LGD adjustments and some other areas, but overall the trend is still a bit down.
And that is why we said our overall risk cost number, in terms of monetary amounts, we expect that to be at around or slightly below the level of what we had last year; and, therefore, if your RWAs would move up a little bit, both effects contribute to a lower risk cost number.
Johnny Vo - Analyst
Okay, great. Thank you.
Operator
Christopher Hitchings.
Christopher Hitchings - Analyst
So many questions, so little time. Can I focus on the interest rate hedges that you've got in place on the VA business and what impact they may have going forward given that interest rates are going up; i.e., what did they have in the fourth quarter and what might they have -- effect they have then?
And I'm looking really at the sources of the -- as it were, the ongoing profit in the Closed VA book. I'm also looking at these model improvements, model updates on your Mortgage book. Can you give us some handle behind what is going on there? Are these ongoing, etc? And also, should we be worried about the rise in non-performing loans in Real Estate, particularly given that your LLCs there seem to have gone down?
Also just a technical thing; when you have sold REIM, will it be that component of profits that will disappear from your P&L account going forward, or are there other impacts?
Thanks.
Jan Hommen - Chief Executive Officer
The interest rate hedge?
Matt Rider - Member of the Management Board Insurance, CAO
Yes, good morning, Chris. On the interest rate hedges, just to recap a bit. What we had announced last quarter was that we would move the VA, or a part of the VA business, the Guaranteed Minimum Withdrawal Benefits more into line with US peers and to put it more on a market value approach.
So during basically the last several weeks of 2010, we've put on a little bit -- about EUR3.7 billion notional of interest rate hedges. Now we actually ended up doing this at a very good time because the interest rates had already increased. So we actually made some small profit I think on the transactions, something like EUR20 million for the fourth quarter.
So at this point, for that block of business, we've locked out about 45% of the exposure to fluctuations in interest rates. So the idea is that as interest rates go up, if they do go up, then we'll benefit for about 55% of the block. If they go down, then we're hedged for about 45%. So all in all, I think that worked out exceptionally well, and we managed to catch the market at a very good time to put those hedges on the books.
Christopher Hitchings - Analyst
Okay, thanks.
Koos Timmermans - Chief Risk Officer
Chris, maybe on the model update on the mortgages, what you see is past experience on recoveries in cases of defaults, you use them in updating your model. So, therefore, you get an LGD, or a loss given default increase, and that is the part what caused the risk cost in the Netherlands to go up.
In fact, you could argue, does it mean we have more defaults? The answer is, no. In fact, what you find is our total amount of arrears has gone down. The only thing -- the effect is if you have an arrear, then you know your costs are going up.
So maybe a slightly confusing answer, but in the end, it's more a past experience driving through in models. Nevertheless, NPL's down there.
If you then move to the Real Estate part, on the Real Estate side you see that we have a little bit more NPLs. I give you a bit of background on those non-performing loans, and that is that all of them are related to covenant breaches. So we are not talking about arrears or non-paying. We have a relatively prudent approach in terms of putting loans in non-performing.
Right, Real Estate.
Patrick Flynn - Chief Financial Officer
In respect to Real Estate [per annum], the impact in the Bank, the profit that we will no longer have is approximately EUR45 million per annum.
Christopher Hitchings - Analyst
EUR45 million per annum. Okay, thank you. Thanks very much.
Operator
Francois Boissin.
Francois Boissin - Analyst
Two or three questions, actually. The first one is on the total capital to be released through the sale of ING Real Estate Investment Management. You mentioned EUR500 million net capital gain. What is the amount of risk-weighted assets decrease here? And, therefore, what's the overall amount of capital released thanks to the transaction?
Second question on WestlandUtrecht; I just wanted to know where you were on that, what you plan to do with -- can we expect something in 2011?
And maybe just finally on ING Direct, the margin; you mentioned trends in Spain and France. What about Germany, the US and the UK, please?
Koos Timmermans - Chief Risk Officer
Yes, if you look at the capital relief, please note that the biggest gain comes from the fact that you sell the Company at a higher than book value. That gives it the capital relief. In terms of capital relief from lower assets, that is not so much the case, because we are selling an investment management company; and, yes, we have a little bit of lower seed capital, but it's relatively small amounts in terms of RWA releases.
Jan Hommen - Chief Executive Officer
On the WestlandUtrecht, we have completed the separation. That was right on time, as we had agreed with the European Commission. We are in the selling process now and cannot tell you much about that process. We're still very active in making sure that we find the buyers and the interested people that could be purchasers of these assets, but nothing to report yet on where we stand on that front.
ING Direct, Patrick?
Patrick Flynn - Chief Financial Officer
Margin development?
Jan Hommen - Chief Executive Officer
Margin.
Patrick Flynn - Chief Financial Officer
On ING Direct, we think margins should be relatively stable on mortgages, as I referred to earlier.
Francois Boissin - Analyst
And how about country specifics, i.e., Germany and US, and particularly where you have big exposures?
Patrick Flynn - Chief Financial Officer
Sorry, could you repeat the question? I couldn't hear you.
Francois Boissin - Analyst
In terms of what's happening in Germany and the US where you have big exposures, basically, do you see stable margins both on loans and deposits, or could you give maybe just a bit more color on that?
Patrick Flynn - Chief Financial Officer
Yes, in terms of the US, there was an uptick in the fourth quarter, and the margins in the US will be -- as I said, that was an accounting one-off effect. So margins would be relatively stable from where they currently are and broadly the same in Germany.
Francois Boissin - Analyst
Great.
Operator
Farquhar Murray.
Farquhar Murray - Analyst
Two questions, if I may. Firstly, just on the interest margin, I wondered if you could give an update of the sensitivity of that to 100 basis point increase in the yield curve. I think previously, you'd guided to 7 basis points on that kind of metric.
Additionally, what are your expectations for and positioning for ECB rate rises? And is any of that captured in the 140 basis points guidance you've given for the next coming quarters?
And then secondly, just on the RWA development, I wondered if you could actually break down the EUR10 billion change q-on-q just between the model changes, underlying growth, and the exchange rate component which we know is EUR3 billion.
Thanks.
Koos Timmermans - Chief Risk Officer
Okay, Farquhar, on the interest rate sensitivity, indeed, we have given initially -- we have given some guidance there on how interest sensitive are we. And indeed, you are talking about 5 basis points to 7 basis points of NIM margin per 100 basis point.
Now if we look at the forward curve, then we are expecting less than a 100 basis point increase for this year. So, yes, this is all part of our medium-term plan and in terms of what our guidance which we are giving. Because in general, what we are doing is we try to make sure that we invest our savings money where interest rates we -- our cost of savings money will go up, but we make sure that our investments are short enough that we do get additional yield out of re-pricing as well.
Farquhar Murray - Analyst
Okay, so there is a little bit of ECB movement built into that 140 basis points?
Jan Hommen - Chief Executive Officer
Yes.
Farquhar Murray - Analyst
Yes. And on the RWA?
Koos Timmermans - Chief Risk Officer
Yes, what was the precise question?
Jan Hommen - Chief Executive Officer
Breakdown of the interest of EUR10 billion.
Koos Timmermans - Chief Risk Officer
If you look at the EUR10 billion, in total what you have is volume growth that is one part EUR5 billion, foreign exchange EUR3 billion; and then we have some model changes approximately a little over EUR10 billion. So that's the negative number. And then we have others, and that is risk migration divestment minus EUR6 billion, so that gives you the complete mix.
Farquhar Murray - Analyst
Okay. And just on the model changes, how comfortable are you that those are captured within the 70 basis points transition to Basel III that you've got, or that you've just given?
Koos Timmermans - Chief Risk Officer
If you talk about the 70 basis point Basel III, so conversion from Basel II to Basel III, we initially guided 70 basis points. And again there, the thing you have to realize as well is revaluation reserve. A negative revaluation reserve, that will have an effect on that. So that makes that 70 basis point deduction a bit more than it was in the past.
And again, that is a little bit the moving part, and there's a few other ones, but this is a bit the bigger moving part there which plays a role, but that is not yet in the capital numbers under Basel II, but under Basel III, that will be the case.
Farquhar Murray - Analyst
Thanks very much indeed.
Operator
Thomas Nagtegaal.
Thomas Nagtegaal - Analyst
I've got two questions. First of all, could you give a bit more details on your expense guidance for the Bank? Now when you say low single digit increase, is it over staff and other costs? Or is it over total expenses which included about EUR40 million in property development impairments in 2010? So if you take those out, the underlying guidance would be significantly higher than low single digit.
And second, I've noticed there is a sharp uptick in the DAC and trail commissions line on the Insurance side. How much of that is recurring and how much of that is one-off?
Thanks.
Patrick Flynn - Chief Financial Officer
In respect to the cost increase, the low single digit is operating expenses, so it excludes -- we're not assuming there's any marketing impacts in there.
Thomas Nagtegaal - Analyst
Okay. So the property development impairments are excluded from that?
Patrick Flynn - Chief Financial Officer
Yes.
Thomas Nagtegaal - Analyst
Okay, clear.
Matt Rider - Member of the Management Board Insurance, CAO
Yes, on the DAC and trail commissions, yes, this is a bit of a funny number because the amortization patterns on DAC in particular vary between whether it's an investment type of product versus whether it's a traditional insurance type of product. But in broad terms what you're seeing is that the DAC and the trail commissions are up, again in broad terms, relative to the amount of operating income that we're getting in. Yes, I think we'll be able to provide a bit more guidance on that one in future calls.
Thomas Nagtegaal - Analyst
Okay, thank you.
Operator
William Elderkin.
William Elderkin - Analyst
I've got three questions, please. First of all, is the Insurance Company's capital structure where you want it to be on a standalone basis, both in respect of the mix of debt and equity, and also in terms of overall capital adequacy from a commercial perspective?
Secondly, in terms of your comments on the Latin American Insurance business, can I take it that you've had material expressions of interest from trade buyers, and so on, and that could be a route that we see you going down?
And then finally, in terms of the payment/repayment of the government capital, would it be fair to see that process as delinked and separate from the sale and divestment of the Insurance operations?
Matt Rider - Member of the Management Board Insurance, CAO
Yes, I think importantly on the Insurance Company capital structure, as we go for two IPOs, remember, the way that we portray the financial leverage is really held at a Group level. So we know that we will need to do some restructuring between a holding company in the United States for a US IPO and a holding company for Asia and a Eurasian IPO.
I think from a commercial standpoint, the most important companies where capital really matters with respect to rating agencies, and so on, we're well capitalized, and no problem on that extent. But I think there will be some certain capital restructuring, and particularly this year.
Jan Hommen - Chief Executive Officer
Okay, on LatAm, what we have said on LatAm is that we are pursuing other strategic options. That means that in addition to looking at does it fit the IPO in the US or Asia, that we're also looking at other options as well. And you are correct, we have had numerous expressions of interest for this type of business.
With respect to the repayment of the Government, we are looking at that separate from the Insurance IPO. We would like to repay this year a significant amount if we could, if we can make an agreement with the Dutch Government. And then I believe that the IPO, the work that needs to be done and the preparation that we need, plus the timing, that it will be much better to look for an IPO or either two of them some time next year more so than this year.
William Elderkin - Analyst
Okay, thank you.
Operator
Nick Holmes.
Nick Holmes - Analyst
A couple of questions, please, on the US Variable Annuity book. The first one is, can you tell us what the confidence level above 50% is? You say that it's significant, but just wondered what it is.
And then also, why don't you take it to the 90% confidence level, which is, I think, the level that you apply for the rest of your reserves? And then also, if you were to do that, what would it cost?
And then the second question is just a general question. What sort of appetite are you seeing for the low cost variable annuities that you're starting to sell? Is it a product basically that you think is going to be successful?
Thanks.
Matt Rider - Member of the Management Board Insurance, CAO
Yes. So in respect of the reserve adequacy level, let's think about it in terms of where we will be as of January 1, right? So we have a number as of December 31, but we also make our equity adjustments as of January 1.
So as of January 1, it would put us about EUR1.1 billion over the 50th percentile level, and I think it works out to be about 73%, something like that on a confidence level basis.
Nick Holmes - Analyst
Okay, right.
Matt Rider - Member of the Management Board Insurance, CAO
Now why don't we go to 90%? Because I think, as we disclosed last time, we really want to run the US business as the US business, and that 90 percentile just simply does not exist in a US GAAP or a US competitor situation. So we don't disclose the number and we don't intend to.
Nick Holmes - Analyst
Okay, fair enough.
Matt Rider - Member of the Management Board Insurance, CAO
And then the appetite for low cost VA; I would say right now, it's very limited.
Nick Holmes - Analyst
Do you see that changing? Do you see consumer demand for these lower cost variable annuities becoming greater and your product approach actually starting to work?
Matt Rider - Member of the Management Board Insurance, CAO
Potentially, but I think right now, other competitors in the US have continued with the more traditional, rich featured, high commission products, and those overtake the low cost versions that we're attempting to sell.
Nick Holmes - Analyst
Okay, and that doesn't bother you; your strategy isn't predicated upon VA expansion?
Matt Rider - Member of the Management Board Insurance, CAO
No, not material at all, because we would intend to grow the US business really largely based on the Retirement Services business, where we have a terrific franchise; and also, the Life Insurance business is fantastic. So those would be the two cores where we would expect to grow there.
Nick Holmes - Analyst
Okay. Thank you very much.
Operator
Michael Van Wegen.
Michael Van Wegen - Analyst
Three questions, please. First of all, on the capital position within the Insurance business, can you update us on your AFR over EC ratio for the end of 2010?
And secondly, can you just confirm that there -- whether there has been any capital been injected in the US business?
And finally, going back to the cost management within the Bank, could you indicate to us what has been the impact from, let's say, restructuring within the bank P&L, so without -- not the special items? And how much of the cost savings that you have been targeting are realized today and how much is still to come?
Thank you.
Matt Rider - Member of the Management Board Insurance, CAO
Let me take the AFR EC information. So what we will do -- we didn't have it any of the disclosure that we've done for this earnings release, but we will publish AFR and EC figures in our annual accounts. But just to give a bit of a preview of those figures, we will give the numbers separately for the Eurasia businesses, including Latin America and the US.
So the AFR EC numbers I'm about to give are for the total Insurance businesses, excluding the US. Going forward, we will run the US as a US insurance company and more focus on RBC ratios, which is traditional for the US.
So for AFR EC for non-US businesses, we have a total AFR of EUR19.7 billion, and in EC of EUR10.4 billion. But what we will intend to do is we will increase the EC by about EUR1.5 billion in order to bring us more into line with where we think that Solvency II is going.
Similarly, on the AFR number, we changed that from a 99 -- or I'm sorry, the EC number, we changed from a 99.95% confidence level to a 99.5% confidence level. Again, this is more to align ourselves with EC -- with Solvency II.
When you work the math out for those businesses, excluding the US, you come to an AFR EC number of 166%, but there will be more disclosure on that in the annual accounts.
For the US businesses, again, we tend to manage that on an RBC basis. We've seen on a preliminary basis some increases in the RBC ratio up to about 432%. And if there were any capital movements, they were de minimis in the fourth quarter.
Michael Van Wegen - Analyst
Okay, thank you.
Jan Hommen - Chief Executive Officer
Sorry, could you repeat the question?
Michael Van Wegen - Analyst
Yes, on the cost basis for the Bank, could you update us, or help clarify to what extent the operating expenses in 2010 will be impacted by restructuring charges in that line rather than in special items?
And secondly, how much of your targeted cost savings have already been achieved and, therefore, in the 2010 numbers, and how much can we see going forward?
Patrick Flynn - Chief Financial Officer
In respect of restructuring charges of special items, yes, we will have special items coming forward in 2011. The biggest components there are likely to include the separation costs that Jan alluded to earlier.
Michael Van Wegen - Analyst
They're outside the Bank P&L, they're in the special item. I mean outside the special items, are there any restructuring charges booked within the Bank for 2010 which will disappear? And how much of the cost savings that you target have already been achieved today, and how much do you expect going forward?
Patrick Flynn - Chief Financial Officer
There's an element -- there's a number of one-off special restructuring charges in special items in 2010 which will not necessarily recur.
Jan Hommen - Chief Executive Officer
Yes, I think the question is what did we realize already. Is that your question?
Michael Van Wegen - Analyst
Yes. How much of your cost savings that you target have you achieved so far? And how much do you expect going forward?
Jan Hommen - Chief Executive Officer
I'd say we have realized about 2% of what we -- 2% reduction in our cost numbers relate to reduction of costs that we have included in the 2010. And we still have plans for further cost reductions. I don't think we have ever disclosed exactly what these plans are, but there still are significant opportunities in IT, in purchasing, and still in a number of other areas where we can significantly reduce our costs.
So our plans are there, but I don't think we have officially mentioned them so far where they are; but you can be assured we are still working on a number of them.
Michael Van Wegen - Analyst
Thank you.
Operator
Jan Willem Weidema.
Jan Willem Weidema - Analyst
I have a question on the comment you just made on economic capital. The increase of EUR1.5 billion at the insurer. How are you going to realize that? That's related to the remaining hybrids in ING Insurance, and do you expect more conversion there?
That is the first question?
Secondly, can you say anything about the long jeopardy impact on the Dutch Insurance operations?
And finally, how comfortable are you with the 5% CAGR for the Bank's underlying income, given that you guide for similar 5% volume growth but lower interest margins?
Matt Rider - Member of the Management Board Insurance, CAO
So I think that the transaction has already been done in December, so it's accomplished and reflected in the balance sheet that you see. Not on that one, no.
Jan Willem Weidema - Analyst
Okay, and do you expect more to come there?
Matt Rider - Member of the Management Board Insurance, CAO
No. Sorry I apologize, I missed your question on longevity.
Jan Willem Weidema - Analyst
Yes, could you comment on what the impact of the impact of the -- life expectancy has been on your Insurance results?
Matt Rider - Member of the Management Board Insurance, CAO
Yes so there's no P&L impact. It does have an impact on the test of reserve adequacy, but that's already baked into our -- it was baked into our capital planning for the year so it has no P&L impact.
Jan Willem Weidema - Analyst
And what has been the impact on shareholders' equity then?
Matt Rider - Member of the Management Board Insurance, CAO
No impact on shareholders' equity either.
Koos Timmermans - Chief Risk Officer
Yes, if you talk about the 5% CAGR, so that is the underlying volume growth. Given the fact that we guide that our margins will stay approximately where they are right now, then the question is by definition that you expect a bit, a positive number on your underlying income.
Jan Willem Weidema - Analyst
Sorry, let me just look at the slides, because on slide 5, you said you still targeted a CAGR of 5% in your underlying income. But if you expect volumes to be up and you expect some pressure on your net interest margin, can you guide us for how you expect to still come to the 5% CAGR in underlying income?
Koos Timmermans - Chief Risk Officer
Yes, I think there's another element which you need to take into consideration; that's your commission income as well. And I think overall what we have given with that long date, it's the long term guidance there where we say like we have that volume increase, and please note that when we two years ago gave that long-term guidance, well, then our net interest margin was even lower than it was right now, because we are still at this north of 140 basis points.
And I think what we just mentioned as well is that our total interest margin is still something which we feel like it can stay at these levels where it is right now approximately. We have some further balance sheet optimization. What we can still do, so that is to try to compress that further with lower income type of business. And we have our Fee business, so we feel comfortable with it.
Jan Willem Weidema - Analyst
Okay, thank you very much.
Operator
Hans Pluijgers.
Hans Pluijgers - Analyst
Two questions, if I may. You already gave some update or indication on the US business respect to Solvency II to bring it in line. That's why you take some measures. Could you give some indication what do you expect to the impact of Solvency II on the capital base for the other Insurance operation, so the Eurasia, LatAm operations?
And secondly, a more detailed question; there were some model changes in the loan loss provisions and that had an impact. You gave some number of the EUR21 million for the US. Could you give an indication what the impact on the model change in the Dutch and German Mortgage book on the loan loss provisions?
Matt Rider - Member of the Management Board Insurance, CAO
So maybe on the first one, if I understand your question well, its alignment of US with Solvency II. But we're not doing that. We're actually trying to align it more with US based principles. So let's a bit take one off the table, and that will be in line with our risk disclosure and so on in the annual accounts. So we don't really consider the US to be a part of Solvency II going forward.
With respect to Solvency II impact on the Eurasian businesses, we're satisfied with our [KIS5] results, but we're not disclosing any specific information on it.
Koos Timmermans - Chief Risk Officer
Yes, and I think if you look at the loan losses, there were a few elements indeed. If you look at the US, it is more the interest accrual on modified loans, which are part of the interest rate line rather than a deduction from your loan losses. And then you're talking about it's somewhere in the -- it's a one-off correction, or something like EUR15 million.
And if you talk about the German and in the Dutch portfolio where we updated our loss given default with some of the experiences, then you are also talking about low teens type of numbers, or EUR20 million. So it is -- net-net I think it is a bit more an illustration that you have to update your models from time to time, but if you correct for these, then you still see an underlying trend which is actually slightly moving down.
Hans Pluijgers - Analyst
Thanks.
Operator
[Marcus Malvalidi].
Marcus Malvalidi - Analyst
A couple of questions, please. It's relating more to slide 28 of the presentation. You were talking about reducing debt leverage, or debt within the Insurance business going forward for rating agency purposes, and yet I see the core debt figure at January 1 is up to GBP7 billion versus I think it was around GBP3 billion on the same slide you posted last year.
Secondly, could you explain, or give a bit a color, please, about the book value increases for Asia Pacific and Benelux over the same period?
And then finally, just on legal restructuring, your Group structure maybe at a very high level seems to be well set up for the two IPO and separate maybe LatAm disposal already, so could you just give some flavor about what legal restructuring needs to be done, and when you'd give the full detail of that as well, please?
Patrick Flynn - Chief Financial Officer
I think the core debt at the Group level is unchanged from the last time we disclosed.
Marcus Malvalidi - Analyst
I'm just looking at the Insurance, ING Insurance section of that presentation. The debt is at GBP7 billion versus GBP3 billion on the disclosure at December 31, '09.
Matt Rider - Member of the Management Board Insurance, CAO
Maybe I take this one. Going forward, we look at the total amount of financial leverage in the Insurance companies, and we see that our definition of core debt had some shortcomings. So what we do is we more align with the way that rating agencies are looking at our total financial leverage. So this is information that you can get right off the balance sheet basically. The core debt involved quite a lot of calculation. So this is I think a better figure to use.
Going forward on the capital structure, I think the increases you saw in the Benelux in particular for IFRS equity largely related to declines in interest rates over the period, and I think you can say about the same thing for Asia Pacific.
Marcus Malvalidi - Analyst
Thank you.
Operator
Lemer Salah.
Lemer Salah - Analyst
I have two questions left. My first question is regards to IPO. You have mentioned previously that you need eight months for conducting an IPO. Why are you still planning to conduct your IPO in 2012? That's my first question.
My question is regards the Eastern Europe issues. As you have noticed, there are a lot of stuff going on like bank imposing bank taxes and centralization of pension asset management towards the Government. What are your success ratio or chances of ING in Eastern Europe?
Thank you very much.
Jan Hommen - Chief Executive Officer
Okay, with respect to the IPO, if the markets would be very attractive in 2011, and if we can accelerate our program, we would certainly take a look at doing it in 2011. But I've given you a more likely scenario. With all the things that we have to do, it is more likely that it will happen in 2012. And that way I think by doing the Dutch Government first, or ideally to do most of that first, we also create additional flexibility in the way that we can execute the IPOs.
With respect to Eastern Europe, Matt is that --?
Matt Rider - Member of the Management Board Insurance, CAO
I apologize; I missed the question.
Lemer Salah - Analyst
Well, I can repeat the question for you. What are the chances of ING in Eastern Europe taking into account that bank taxes are imposed in Eastern Europe? For example, Hungary, Poland, going forward, that other countries will conduct similar actions, and also the centralization of pension will?
Matt Rider - Member of the Management Board Insurance, CAO
Yes, it maybe a tale of two cities here. I think, clearly, we're facing challenges in the regulatory environment in Hungary and Poland, but by the same token, the question is to what extent will normal people want more access to more private pension funds?
So a bit we lose out on the mandatory side, but there is at least a glimmer of hope that we could capitalize on the opportunity for more private funds.
Koos Timmermans - Chief Risk Officer
Yes, and maybe to add on the Bank side. If you follow our Eastern European activities there, in essence, what we are doing is collecting savings; supplying mortgages and supplying money to the economy. We are not into a very speculative or financial markets type of business over there. So somewhere we feel that despite the fact that you get an occasional bank tax, that it does not change your structural plans to move forward in these markets. So, no, we are still quite positive about that.
Operator
Federico Salerno.
Federico Salerno - Analyst
Two things on the Insurance side. A, was wondering if you plan to carry out a re-risking of the Insurance balance sheet in the coming months.
And number two, can you give us sensitivity of the Variable Annuities book to equity markets, like you used to previously?
Thanks.
Matt Rider - Member of the Management Board Insurance, CAO
So on the first one I think what you've seen in the overall Insurance book is the increase in the investment margin that we have. It's partly due to some moderate re-risking. We really want to take this slowly. You saw that we made some good progress from the overall investment margin moving from 83 basis points to 93 basis points. Our overall target by 2013 is 105 basis points. So in this one, we want to do this in a very much of a moderated approach.
With respect to earnings sensitivities on the VA business, I think what you're going to see is basically not a lot of impact relative to equity market movements within a band of about plus or minus 5%. What you will see though as you get into work streams, and let's say plus or minus 10%, you'll see probably a negative GBP50 billion euro sensitivity around that number. The reason on the -- when equity markets go up, we still have some [hedge] asymmetry; when equity markets go down, we lose out on fees.
So what you'll see is within that, within a 5% range, not a lot of impact; once you get out into the extremes, let's say about EUR50 million.
Operator
Tony Silverman.
Tony Silverman - Analyst
Just have a couple of questions left, please. In general terms, the IPOs that you're contemplating, do you contemplate for the Insurance IPOs they will in effect be a complete sale? Or do you contemplate being left with some stake? If so, perhaps you could elaborate on that.
And in connection with that, in answer to an earlier question, you mentioned that there may be some further capital restructuring for the Insurance companies in Asia and the US. Can you tell us if that would involve less than EUR5 billion going into them? Or would it an immaterial amount anyway?
And the second question was around the Closed Block again. The markets and other impacts, the narrative, I think it's on page 34 of the report, refers to EUR150 million charge to do with interest rates going up in Q4. I wonder if you could talk a bit about that. You've mentioned the sensitivity to equities in the previous question, but the charge for interest rates going up for in respect of guarantees, seems to be slightly counter-intuitive to me. I'd be interested to hear more.
Thank you.
Jan Hommen - Chief Executive Officer
Okay, let me do the first one that asks the question related to the IPO. Well, let's first take a look at what the markets are at the time that we do the IPO, and then we can decide what exactly our strategy will be.
At the end, I think we want to have 100% sale, but most of the time you don't do that in an IPO; you have a more moderate position that you saw first, let's say 25% to 40%; and then later you come back with additional tranches. But let's wait until we know exactly what it is, where we are and what markets we are in, before we make any predictions here.
The second question will be answered by Matt.
Matt Rider - Member of the Management Board Insurance, CAO
So first on the capital structure; we're not really anticipating any injection of capital into these companies. It's more restructuring of debt and hybrids. And that will begin to take place over the first half of the year. But it mainly has to do with rejiggering a bit debt and hybrids in a US holding company versus a Eurasian holding company. So that's really what we intend to do.
With respect to the EUR150 million number that you see on page 34 of our quarterly report, it doesn't relate to the VA Closed book. It relates to a certain business. It's basically separate account pension business within the Netherlands where we have an imperfect hedge on. And what you see with this thing is when there are -- the hedge works within a reasonably narrow band of interest rates and equity movements, but when you have particularly big increases in interest rates, then you start to see the small utility come through.
You've actually seen it in prior quarters and it's described a bit better when you get into the Benelux section. So we know that this number is quite volatile, but if you look at that figure over the course of the year, it ended up being, I think, positive EUR25 billion. But there is some volatility in that number.
Tony Silverman - Analyst
Right, thank you very much. Can we just come back on the restructuring of debt and hybrids that you mentioned? Is that basically essentially cheating equity for those debt and hybrids, or something else.
Matt Rider - Member of the Management Board Insurance, CAO
No, it's just again where we're holding certain instruments within the US holding company. We're holding certain instruments within ING Verzekeringen, which is the holding company for overall Insurance. And there probably needs to be some movement between the two, but we're not talking about additional capital or anything of that nature.
Jan Hommen - Chief Executive Officer
And I think we need to be a little careful here, because we have not done our complete evaluation analysis yet, and I think we will be extremely cautious and careful in how that will be accomplished. So this is still work to be done and still work to come. We can report better I think when we get closer to that than we can at this moment.
Tony Silverman - Analyst
Thank you very much.
Operator
Manish Bakhda.
Manish Bakhda - Analyst
My question is just on CoCos, and I noticed back in December there were some comments from ING suggesting that you were looking at developments in the CoCos market. I just wanted to know if you had any updates on that, please.
Koos Timmermans - Chief Risk Officer
Manish, we're always looking, but we are certainly very carefully looking at -- I recognize CoCos, I recognize high coupons of 9.5% which you see in the market as well. But you want to be sure like what is it that you get from this. So it's a market which we are following, but at the same time there is no concrete plans yet that we start to issue something like it. You want some more clarification on regulation; you want some more clarification on where does it help you in terms of buffers. And at the same time, we still have the old grandfathering of the old hybrids, so we are not in a hurry to do something there. But of course, if there is a new market, there is new opportunities, so from that angle we will certainly look at this.
Manish Bakhda - Analyst
Okay, thank you very much for that.
Operator
Marcus Malvalidi.
Marcus Malvalidi - Analyst
Sorry I'm just coming back, because I think my last question actually wasn't - -I was cut off before you could answer it. It was about the legal restructuring you're talking about? In your Group structure, you seem to be pretty well set up already for the disposal that you've been talking about. Could you just give some color about what you're actually going to be doing there in terms of restructuring it and when we'll get the concrete decisions around that?
Jan Hommen - Chief Executive Officer
Second is very simple. What we plan to do is we need to make sure that if we take the US operations and want to go public with them that we have properly structure that in that our legal structure. And that is the main thing that I think we need to be doing at this moment as part of our redesign of doing two IPOs. That is the main, let's say, legal issue that is there.
For the Latin American business, whatever we do, we can either put it with the US, or we can put it with Europe, or we can, let's say, have other options. It's already positioned to do that. So there will not be too much work on that side.
Operator
Farooq Hanif.
Farooq Hanif - Analyst
Thanks for taking a follow-up question. I just wanted to ask about your capacity to repay the Dutch Government this year from internal resources. Leaving aside the question of the amount of penalty you may or may not have to pay, can you comment on that?
Jan Hommen - Chief Executive Officer
Not really that much. I can only say that we have an intention to repay at least a significant amount. We also need to be mindful of the higher requirements of Basel III. We need to be mindful of there are other things still happening in the world. And, of course, we are generating income. And all that together I think will determine at some point how much we have available from internally generated activities. Plus we are maybe still planning to do some transactions in the meantime as well, some sales, divestments that can also generate capital and funds.
So all that together will determine to what extent we have the ability to pay back and the amount we can pay back.
But everything is taken into account. The one thing we are not counting on, and we are not excluding, is that we will go back to the market for more capital. We don't want to do that. We want to do it as internally generated funds.
Farooq Hanif - Analyst
Okay, that's very clear. Thank you.
Operator
(Operator Instructions). Jan Willem Weidema.
Jan Willem Weidema - Analyst
Yes, sorry; one follow-up question following also what Farooq just asked. What kind of core Tier 1 level will you be looking for in the Bank after you've repaid the stated 7.5%, which is the old guidance for maybe looking more towards 8% or higher with a view to Basel III.
Jan Hommen - Chief Executive Officer
I think we have already answered that earlier. I think. Koos answered that we would not like to see it go down below the 8% level, and we need to be comfortable as well. So this is a moving number. Over time it might even go higher than that. We don't know yet. There's still too many issues we need to determine. But it's higher than the 7.5%. It's certainly higher than 8%.
Jan Willem Weidema - Analyst
Okay. Thank you.
Operator
There appear to be no more questions at this time. Please continue.
Jan Hommen - Chief Executive Officer
If there are no more questions, then I thank you for your attendance. I wish you a very good day and maybe we'll see you soon.
Thanks a lot. Bye-bye.
Operator
Thank you. This does conclude your conference call for today. Thank you for your participation. You may now disconnect.