ING XBRL Proof of Concept July 19, 2005

©2005 page 2. Utilizing XBRL  ING Objectives  Benefits  Goals  Proof of Concept Plan  Stat  USGAAP  Pain Points  Technology  Taxonomy  Observations

©2005 page 3. XBRL Benefits for ING  Increase efficiency of Internal Reporting  Tag source data element at the ledger increasing data re-usability  Utilize tagged information in multiple reporting requirements  Increase reporting automation  Reduce manual keying errors for same data used in different venues and formats, i.e. improve quality  Naming convention standardized for tagging data elements Tagging just reporting line item data was not of interest as it would not increase efficiency but add an additional step to reporting process

©2005 page 4. ING Objectives  Enable XBRL functionality in general ledger system that can:  Streamline operations Eliminate manual keying of information Data supplied once for multiple reporting needs  Improve visibility to financial data Standardized tags allows audit trail of where data is being utilized  Enhance the understanding of financial results Standard definitions and technical references for data elements  Volunteer to be XBRL filer with SEC  Create standard reporting of financial data that can be absorbed by any unit within ING  Create instance document that can be read by parent in Netherlands

©2005 page 5. Information Supply Chain with XBRL Accounting System Other Sources of Information Element Tag, Instance Document, Style Sheet Regulatory Filings Source Elements XBRLReporting Printed Financials Web Site Tax Returns Bank Filings  From Software AG white paper

©2005 page 6. ING - XBRL Proof of Concept Plan  Utilize new XBRL functionality in general ledger upgrade and statutory reporting software  Create XBRL instance files from ledger for SEC reporting  Create instance document for Balance Sheet, Income Statement, Shareholder’s Equity and Statement of Cashflow  Verify data through readable presentation of instance document  Report financial pages to SEC with XBRL instance documents  Create XBRL instance files from ledger for financial pages of statutory reporting  Develop statutory insurance taxonomy  Build interface to load instance document (ledger data) into Wings  Eliminate manual keying of data into Statutory reporting software and state filing form requirements  Assumption: GL package would provide full XBRL tool-set

©2005 page 7. Proof of Concept Pain Points  Complexity of ING reporting structure  Multiple ledgers  Size of chart of accounts  Legal and operating entity structure  Delivered GL XBRL functionality did not work out of the box  Underlying taxonomy outdated  Could not reference industry specific taxonomy  No presentation component – instance document only  Multiple ING customizations in order to produce instance document:  Removing hard coded (demo) setup  Modification to allow multiple business units and ledgers  Modification to correct totals for business units and ledgers along with the Chartfield value sets  Additional functionality required:  Prior year context extraction in the instance document  Calculated fields that summarize reverse sign values  Automated process for consumption of taxonomies  Current and prior year context within one instance document  Conditional tagging – if positive or if negative

©2005 page 8.

©2005 page 9. Observations  ING XBRL proof of concept put on hold for further evaluation of approach  No known current insurance user of our GL XBRL functionality  Additional software requirements to utilize XBRL:  For calculation capability (e.g., Tag 1 minus Tag 2)  For creation of reporting document for verification  For maintaining taxonomy  Significant up-front business analysis required  Detail understanding of compilation of ledger data to financial statement  Analysis of ING specific reporting requirements versus standard taxonomies

©2005 page 10. Conclusions  XBRL is a tremendous reporting tool; however,  Current software applications tend to be first generation:  General ledger systems need to better understand how XBRL functionality will be utilized and reference current taxonomies  Spreadsheet add-ins would increase adaptability  Currently, investment in new software required  Working with GL vendor to establish focus group of insurers to develop financial reporting solutions, including XBRL  To tag source data, significant up-front business analysis:  Application of account definition consistent across reporting venues  Understanding the amount of data outside ledger system  Understanding what custom tags will be required