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Wholesale Banking

ING Capital Markets LLC (INGCM)

ING Capital Markets LLC (INGCM) is a Delaware limited liability company and a wholly-owned indirect subsidiary of ING Bank N.V. INGCM is registered with the Commodity Futures Trading Commission as a full service swaps dealer. INGCM acts as a counterparty to its Domestic and International client base in a broad variety of product offerings including but not limited to FX, Rate, Equity and Commodity. For further information, please contact one of our product representatives for a solution that is right for your needs.

Katharyn MeyerHead of Rates and Credit Trading+1(646) 424-6083
Christine GinfridaHead Corporate Sales+1(646) 424-6116
Juan HerreraHead Financial Institution Sales+1(646) 424-6674

Or you can e-mail us at ING Capital Markets.

Statements of Financial Condition

Clients may obtain ING Capital Markets Statement of Financial condition below.




INGCM is providing to its counterparties on this website certain standardized swap disclosures which are required under the External Business Conduct rules of the CFTC and SEC. You should review these disclosures as well as any information set forth in the links provided herein. In addition to the disclosures contained on this website, you should read carefully any additional disclosures contained in any documentation provided to you from time to time by your INGCM sales representative.

The informational disclosures are provided to you in connection with certain rules and regulations, pursuant to which ING Capital Markets LLC (“ING Capital Markets”), as a registered “swap dealer” and registered “securities based swap dealer”, is required to provide to certain of its counterparties prior to trading certain over-the-counter derivative and foreign exchange products. You should read the following disclosures carefully:

Prior to entering into a swap that is not made available for trading, on a designated contract market or swap execution facility that is transacted with a Non-Swap Entity counterparty, INGCM shall upon request, provide a Scenario Analysis. All material assumptions and explanations to the calculation methodologies used will be provided within the scenario analysis. Such Scenario Analysis may include a range of assumptions, including those it undertakes for its own risk management purposes, including analyses performed as part of its New Product Policy, and downside stress scenarios. INGCM is available to consult on the design of a scenario analysis to assess potential exposure in connection with the swap. If you wish to obtain such Scenario Analysis please contact your ING Capital Markets representative.

For the Mark-to-Market disclosure, please read this document.

For the Conflicts of Interest disclosure, please read this document

For the Initial Margin Segregation disclosure, please read this document.

Material Economic Terms

The below external links provide information including standard product terms and sample industry confirmation templates for various asset classes:


Pre-Trade Disclosures

Prior to entering into any swaps with a Non-Swap Entity, we will communicate to you what we believe to be the material economic terms of the swap as well as the pre-trade mid-market mark for certain swaps. You should also refer to any documentation that INGCM has sent to you or that we have previously executed, including, but not limited to, any master agreement, master confirmation agreement, confirmation (including any confirmation relating to a prior swap), term sheet or other summary of economic terms. Please communicate with your INGCM representative if you believe that any material economic terms of a swap have not been provided to you.
Documentation provided to you by INGCM may reference certain other documents and definitions, including those published by ISDA. Any such referenced documents or definitions (including those found at the ISDA Bookstore are available from your INGCM representative upon request. For your convenience we have included on this website some standard ING swap templates.

Additional information, including standard product terms, other confirmation templates and market conventions for various asset classes may be found in the Material Economic Terms above.

By entering into a swap with INGCM you will be deemed to have acknowledged that you have received from INGCM prior to entry into such swap the relevant disclosures, notifications and other information sufficient for you to evaluate the material risks and characteristics of such swap.

Upon request, a Scenario Analysis is available to each Non-Swap Entity counterparty. Such Scenario Analysis may include a rage of assumptions, including downside stress scenarios. If you wish to obtain such Scenario Analysis please contact your ING Capital Markets representative.

Recording of Conversations

INGCM may record telephone conversations between or among INGCM personnel and third parties. These recordings may be used for regulatory purposes or be submitted in evidence in any proceedings.

Suitability Disclosure

Generally speaking INGCM does not make recommendations to clients as it relates to derivative transactions. ING Capital Markets is acting in its capacity as a counterparty and is not undertaking to assess the suitability of the swap or trading strategy involving a swap for the counterparty.

Clearing Disclosure

For counterparties who are not Swap Dealers, Major Swap Participants, security-based swap dealers or major security-based swap participants you are entitled to the following rights:

  • (a) in connection with each swap that is subject to mandatory clearing, you have the sole right to select the derivatives clearing organization through which the transaction will clear; and
  • (b) in connection with each swap not subject to mandatory clearing, you have the right to require clearing of the swap and select the derivatives clearing organization through which the transaction will clear.

Listing of INGCM DCOs

  • (c) INGCM currently utilizes LCH via an affiliate as DCO

Alternative Compliance Mechanism

In accordance with 17 C.F.R. 240.18a-10 (the “Alternative compliance mechanism”), ING Capital Markets LLC intends to operate under 17 C.F.R. 240.18a-10 beginning on the date of its registration as a Security-Based Swap Dealer on or before November 1, 2021.


Complaints should be directed to the John McCarthy, Chief Compliance Officer.
By Phone: +1 646-424-6785
By E-mail: John.McCarthyCompliance@ing.com

Alternatively, you can write to us at the address below.
ING Capital Markets LLC
1133 Avenue of the Americas
New York, NY 10036