Public Comment Dividend Requirements ING Direct

August 16, 2006 Robert E. Feldman, Executive Secretary Attention: Comments Federal Deposit Insurance Corporation th550 17 Street, N.W. Washington, D.C. 20429 RE: RIN 3064-AD08: Proposed Rulemaking Implementing the One-Time Assessment Credit RE: RIN 3064-AD02: Proposed Rulemaking Setting the Designated Reserve Ratio for 2007 RE: RIN 3064-AD07: Proposed Rulemaking to Specifying Dividend Requirements Dear Mr. Feldman: ING Bank, fsb (“ING DIRECT”) provides retail banking services and financial products 1to individuals and businesses across the United States. Chartered in August 2000, in six years ING DIRECT has grown from nothing to a savings bank with assets of $61 billion and deposits of $46 billion, while consistently remaining well-capitalized. ING DIRECT has done so through innovation and a strict focus on its brand vision: leading Americans back to saving. ING DIRECT appreciates the opportunity to provide comment as part of the Federal Deposit Insurance Corporation’s (“FDIC’s”) proposed rulemaking proceedings: (1) Implementing the one-time assessment credit required by section 7(e)(3) of the Federal Deposit Insurance Act (“FDI Act”) as amended by the Federal Deposit Insurance Reform Act of 2005 (“FDIRA”); (2) Setting the Designated Reserve Ratio (“DRR”) for 2007; and, 1 Later that year, as a consequence of a merger of their holding companies, ING DIRECT ...