Insurance Overview

To mitigate the environmental and social risks of its financial engagements, ING has developed the Environmental Social Risk (ESR) Management Framework. The Framework consists of a set of three policies:

1. General Policies (see below)

2. Sector-Specific Policies

3. Equator Principles

All wholesale banking activities (e.g. corporate loans, export and commodity finance, project finance, advisory services and client engagement in general) are within the scope of the ESR Framework.

The General ESR Policies cover topics such as:

• Animal testing
• Defence/controversial weapons
• Environmental compliance
• Fur
• Gambling
• Genetic Engineering
• Human Rights
• Nuclear energy
• Pornography
• Tobacco

ING Direct UK offers an LTV (loan-to-value) rate of up to 75% and an LTI (loan-to-income) rate of 4 times gross income on a single application. The LTV rate compares favourably with suggestions made in the FSA’s Turner Review that a maximum of 90% of a property’s price be loaned i.e. that borrowers should have at least a 10% deposit for a mortgage. The same review, however, suggests LTI should be 3.5 times the annual wage of a single mortgage applicant. ING states that it uses income multiples as a guide for customers but that affordability checks take precedent in determining how much it will lend. 

In terms of credit checking, the bank states that it uses information from both credit reference agencies and a credit scoring system to determine borrower suitability. 

2. Debt Warning

The bank issues the generic warning: ‘Your home may be repossessed if you do not keep up repayments on your mortgage.’

The bank does not use the FSA Debt Test. This test is designed to help customers find out whether they have, or are likely to have, problems with borrowing. It also has tips on what to do if customers find themselves in difficulty. 

3. Debt Management and Advice 

With regard to policies on payment default and handling payment problems, ING Direct has a policy ‘Treating Customers Fairly in Arrears’, which lays out assistance it ‘might’ offer as follows:

• Talk to an agency which gives debt advice (for example, Citizens Advice), if requested
• Give the customer ‘reasonable time’ to pay back the debt
• Arrange a new payment plan
• Change the date payments are made
• Allow the customer to pay back their mortgage over a longer period of time, reducing monthly payments
• Change the type of mortgage 

The bank also outlines the process of repossession and the possible consequences if the sale of the house does not generate enough money to repay the full mortgage amount. 

The bank states that up to three payment holidays can be taken in any 12-month period, but no more that six during the mortgage term. The circumstances under which payment holidays may be granted are outlined in the mortgage terms and conditions. The bank also supplies a calculator for customers to work out the impact of taking payment holidays on their repayments. 

No information was found as to whether the bank offers re-housing advice or liaises with organisations such as Shelter and the Citizens Advice Bureau to work out re-housing arrangements with mortgage customers facing re-possession. 

NG Group’s Environmental Statement, which applies to all operations, explicitly addresses energy consumption, business travel and paper consumption, but not waste management. However ING monitors and reports data for waste management, energy and water usage in its Corporate Social Responsibility report.

No commitment to the continued improvement of ING Direct (UK) or ING Group’s environmental performance was found.