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 and the Securities and Exchange Commission as a security based 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.
| Tyrel Tugade | Head of Trading | +1(646) 646-6104 |
| Christine Ginfrida | Head Corporate Sales | +1(646) 424-6116 |
| Juan Herrera | Head 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.
2021
2022
2023
Disclosures
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 INGCM, 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:
- General Disclosure
- Product-Specific Disclosures:
- IBOR Alternative Reference Rates
Daily Marks
Cleared Transactions: for cleared swaps originally executed with INGCM, you have the right to receive the daily mark from the relevant derivatives clearing organisation upon Un-Cleared Transactions.
For the Mark-to-Market disclosure, please read this document.
Conflicts of Interest
For the Conflicts of Interest disclosure, please read this document.
Initial Margin Segregation
For the Initial Margin Segregation disclosure, please read this document.
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.
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.
Scenario Analysis
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
ING Capital Markets LLC relies on 17 C.F.R. 240.18a-10 (the “Alternative compliance mechanism”) and complies with the applicable capital, margin and segregation requirements of the Commodity Exchange Act and the rules promulgated by the U.S. Commodity Futures Trading Commission thereunder in lieu of complying with the capital, margin, and segregation requirements promulgated by the U.S. Securities and Exchange Commission in 17 CFR 240.18a-1, 17 CFR 240.18a-3 and 17 CFR 240.18a-4. Notwithstanding the foregoing, any disclosure regarding operation under the Alternative compliance mechanism will no longer be applicable if ING Capital Markets LLC subsequently discloses in writing that it no longer intends to operate under the Alternative Compliance Mechanism.
Complaints
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
U.S.A.