Voya 2013 Annual Report Download - page 410

Item 9. Changes in and Disagreements With Accountants on Accounting and Financial Disclosure
None
Item 9A. Controls and Procedures
The Company carried out an evaluation, under the supervision and with the participation of its management, including
its Chief Executive Officer and Chief Financial Officer, of the effectiveness of the design and operation of the
Company’s disclosure controls and procedures (as defined in Rule 13a-15(e) and 15d-15(e) of the Securities Exchange
Act of 1934, as amended (“Exchange Act”)) as of the end of the period covered by this report. Based on that
evaluation, the Chief Executive Officer and the Chief Financial Officer have concluded that the Company’s current
disclosure controls and procedures are effective in ensuring that material information relating to the Company required
to be disclosed in the Company’s periodic SEC filings is made known to them in a timely manner.
This annual report does not include a report of management’s assessment regarding internal control over
financial reporting or an attestation report of the Company’s registered public accounting firm due to a transition
period established by rules of the Securities and Exchange Commission for newly public companies.
Item 9B. Other Information
Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012, which was signed into law on
August 10, 2012, added a new subsection (r) to Section 13 of the Securities Exchange Act of 1934, as amended
(the “Exchange Act”), which requires us to disclose whether the Company or any of its affiliates, including ING
Groep N.V. (“ING Group”) or its affiliates has engaged during the year ended December 31, 2013 in certain Iran-
related activities, including any transaction or dealing with the Government of Iran that is not conducted pursuant
to a specific authorization of the U.S. Government.
Neither ING U.S., Inc. nor any of its subsidiaries, have knowingly engaged in any transaction or dealing
reportable under Section 13(r) of the Exchange Act during the year ended December 31, 2013. The disclosure
below relates solely to a limited legacy portfolio of guarantees, accounts, loans and relationships maintained by
ING Bank N.V. (“ING Bank”), a subsidiary of ING Group and therefore an affiliate of ING U.S., Inc., and does
not relate to any activities conducted by ING U.S., Inc. or its subsidiaries, or involve the management of ING
U.S., Inc. or its subsidiaries.
Other than the transactions described below, at no time during the year ended December 31, 2013 did ING Group
or any of its affiliates knowingly conduct or engage in any activities that would require disclosure to the U.S.
Securities and Exchange Commission pursuant to Section 13(r) of the Exchange Act. ING Bank maintains a
limited legacy portfolio of guarantees, accounts, and loans that involve various entities owned by the
Government of Iran. ING Bank also has limited legacy relationships with certain persons who are designated
under Executive Orders 13224 and 13382. These positions remain on the books, but accounts related thereto may
be ‘frozen’ under applicable laws and procedures. In such cases, any interest or other payments ING Bank is
legally required to make in connection with said positions are made into ‘frozen’ accounts. Funds can only be
withdrawn by relevant parties from these ‘frozen’ accounts after due regulatory consent from the relevant
competent authorities. ING Bank has strict controls in place to ensure that no unauthorized account activity takes
place while the account is ‘frozen’. ING Bank may receive loan repayments, but all legacy loan repayments
received by ING Bank have been duly authorized by the relevant competent authorities. For the year ended
December 31, 2013, ING Bank had gross revenues of approximately $13.5 million related to these activities,
which was principally related to legacy loan repayment. ING Bank estimates that it had net profit of
approximately $448.7 thousand related to these activities. ING Bank intends to terminate each of the legacy
positions as the nature thereof and applicable law permits.
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