Voya 2013 Annual Report Download - page 64

purchase the INT entity itself. The transactions contemplated by the Purchase and Assumption Agreement are
expected to be consummated prior to or during 2015.
ING Investment Trust Co., our wholly owned subsidiary, is a limited purpose trust company chartered with
the Connecticut Department of Banking. ING Investment Trust Co. is not permitted to, and does not, accept
deposits (other than incidental to its trust activities). ING Investment Trust Co.’s activities are primarily to serve
as trustee for and manage various collective and common trust funds. ING Investment Trust Co. is subject to
regulation, supervision and examination by the Connecticut Banking Commissioner and is subject to state
fiduciary duty laws. In addition, the collective trust funds managed by ING Investment Trust Co. are generally
subject to ERISA.
Financial Reform Legislation and Initiatives
Dodd-Frank Wall Street Reform and Consumer Protection Act
On July 21, 2010, President Obama signed into law the Dodd-Frank Act, which effects comprehensive
changes to the regulation of financial services in the United States. The Dodd-Frank Act directs existing and
newly-created government agencies and bodies to conduct certain studies and promulgate a multitude of
regulations implementing the law, a process that is underway and is expected to continue over the next few years.
While some studies have already been completed and the rule-making process is well underway, there continues
to be significant uncertainty regarding the results of ongoing studies and the ultimate requirements of those
regulations that have not yet been adopted. We cannot predict with certainty how the Dodd-Frank Act and such
regulations will affect the financial markets generally, or impact our business, ratings, results of operations, cash
flows or financial condition.
The Dodd-Frank Act created a new agency, the FSOC, which is authorized to subject nonbank financial
companies to the supervision of the Federal Reserve if the FSOC determines that material financial distress at the
company or the scope of the company’s activities could pose risks to the financial stability of the United States.
If we were designated by the FSOC as a systemically significant nonbank financial company subject to
supervision by the Federal Reserve, we would become subject to a comprehensive system of prudential
regulation, including, among other matters, minimum capital requirements, liquidity standards, credit exposure
requirements, maintenance of resolution plans, stress testing, management interlock prohibitions, additional fees
and assessments and restrictions on proprietary trading and other investments (including restrictions similar to
the so-called “Volcker Rule” on our proprietary trading activity or our ability to sponsor or invest in certain types
of investment funds). The exact scope and consequences of these standards and requirements are subject to
ongoing rulemaking activity by various federal banking regulators and therefore are currently unclear. However,
this comprehensive system of prudential regulation, if applied to the Company, would significantly impact the
manner in which we operate and could materially and adversely impact the profitability of one or more of our
business lines or the level of capital required to support our activities. As long as the Company continues to be
controlled by ING Group, the FSOC may consider the Company together with ING Group’s other operations in
the United States for purposes of making this determination. Therefore, while we believe it is unlikely that the
Company, either on a standalone basis or together with ING Group’s other operations in the United States, will
ultimately receive this designation, there is a greater likelihood of such a designation being made for as long as
we are controlled by ING Group.
In addition, the Dodd-Frank Act contains numerous other provisions, some of which may have an impact on
us. These include:
• The FSOC may recommend that state insurance regulators or other regulators apply new or heightened
standards and safeguards for activities or practices we and other insurers or other financial services
companies engage in if the FSOC determines that those activities or practices could create or increase
the risk that significant liquidity, credit or other problems spread among financial companies. We
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