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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 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 derivatives. For further information, please contact one of our product representatives for a solution that is right for your needs.

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 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:

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

Portfolio Reconciliation

Portfolio reconciliation is a post-execution processing and risk management technique that is designed to: (i) Identify and resolve discrepancies between the counterparties with regard to the terms of a swap either immediately after execution or during the life of the swap; (ii) ensure effective confirmation of all the terms of the swap; and (iii) identify and resolve discrepancies between the counterparties regarding the valuation of the swap. In some instances, portfolio reconciliation also may facilitate the identification and resolution of discrepancies between the counterparties with regard to valuations of collateral held as margin.

Accordingly, the CFTC enacted 17 CFR § 23.502, which requires Swap Dealers (SDs) and Major Swap Participants (MSPs) to reconcile their swap portfolios with one another and provide counterparties who are not registered as SDs or MSPs with regular opportunities for portfolio reconciliation.  The SEC has enacted a parallel rule (17 CFR § 240.15Fi-3) for Security-Based Swap Dealers (SBSDs) and Major Security-Based Swap Participants (MSBSPs).

In addition to other obligations, these rules require INGCM, as a registered SD and SBSD, to (i) with respect to each counterparty that is a SD, MSP, SBSD or MSBSP, agree in writing on the terms of portfolio reconciliation and (ii) with respect to all other types of counterparties, maintain and follow written policies and procedures reasonably designed to ensure there is a written agreement on the terms of portfolio reconciliation.  INGCM satisfies this obligation through one of the following methods:

  • Confirming customers have agreed to Portfolio Reconciliation under Schedule 4 of the ISDA March 2013 DF Protocol, either via elections on Markit’s ISDA Amend website or via bilateral Dodd-Frank protocol adherence documentation exchanged between INGCM and its customers; or
  • Agreeing to terms of portfolio reconciliation via a separate written agreement between ING and the customer. 

For additional information:

eCFR :: 17 CFR 23.502 -- Portfolio reconciliation

eCFR :: 17 CFR 240.15Fi-3 -- Security-based swap portfolio reconciliation

ISDA March 2013 DF Protocol – International Swaps and Derivatives Association

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

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