Voya 2014 Annual Report Download - page 113

laundering, prohibited transactions with countries subject to sanctions, and bribery or other anti-corruption
measures. The financial market dislocations we have experienced have produced, and are expected to continue to
produce, extensive changes in existing laws and regulations applicable to our businesses.
Compliance with applicable laws and regulations is time consuming and personnel-intensive, and changes in
laws and regulations may materially increase the cost of compliance and other expenses of doing business. There
are a number of risks that may arise where applicable regulations may be unclear, subject to multiple
interpretations or under development or where regulations may conflict with one another, where regulators revise
their previous guidance or courts overturn previous rulings, which could result in our failure to meet applicable
standards. Regulators and other authorities have the power to bring administrative or judicial proceedings against
us, which could result, among other things, in suspension or revocation of our licenses, cease and desist orders,
fines, civil penalties, criminal penalties or other disciplinary action which could materially harm our results of
operations and financial condition. If we fail to address, or appear to fail to address, appropriately any of these
matters, our reputation could be harmed and we could be subject to additional legal risk, which could increase the
size and number of claims and damages asserted against us or subject us to enforcement actions, fines and
penalties. See “Item 1. Business—Regulation” for further discussion of the impact of regulations on our
businesses.
The Health Care Act significantly impacts how employers provide health care to employees and how
individuals obtain health care insurance. There is uncertainty surrounding the impact of the Health Care Act on
insurers which may create risks to products we offer, including Stop Loss Insurance sold to employers offering
self-insured health plans. In addition, should the Treasury Department issue guidance concluding that insurers
offering Stop Loss Insurance are considered health care providers, we may face adverse tax or other financial
consequences.
To the extent that we remain affiliated with ING Group, we may be subject to laws, regulations, disclosures
and restrictions to which we would not be subject without such affiliation. These restrictions could be extensive
and include limitations on the activities we may conduct and the way in which we organize and operate our
businesses. Various jurisdictions in which ING Group and its subsidiaries operate, including the United States,
apply prudential and other regulations to the holding companies and affiliates of financial institutions. If the
applicable laws and regulations in any of these jurisdictions, or the application or interpretation of such laws and
regulations by applicable regulators and other authorities, were to change, or if ING Group or one of its
subsidiaries were to change the nature of the regulated activities they conduct, we could in the future become
subject to restrictions to which we are not currently subject, and to which we would not be subject as a
standalone enterprise. This could require us to incur material compliance, reporting or other costs or to forego
certain types of material revenues or we could otherwise be confronted with consequences that are material and
adverse to us. We do not have any control over the activities conducted by ING Group or its subsidiaries.
In addition, the 2012 Amended Restructuring Plan contains provisions that could limit our business
activities, including restricting our ability to make certain acquisitions. See “Item 1. Business—Regulation—
Dutch State Transactions and Restructuring Plan”.
If ING Group or one of its subsidiaries were to change the nature of the regulated activities it conducts, we
could in the future become subject to restrictions to which we are not currently subject, and to which we would
not otherwise be subject as a standalone enterprise.
As long as ING Group continues to be a significant shareholder of the Company, we may be subject to laws,
regulations, disclosures and restrictions to which we would not be subject as a standalone enterprise. These
restrictions could be extensive and include limitations on the activities we may conduct and the way in which we
organize and operate our businesses. For instance, ING Group’s wholly owned subsidiary, ING Bank, may from
time to time consider whether to establish a branch office in the United States. If ING Bank were to establish a
U.S. branch, ING Group and ING Bank would be subject to supervision and regulation by the Federal Reserve
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