Don't forget ING diluted from 2.1B shares in 2007 to 3.8B today since the price was $40+. So even at the same earnings and valuation metrics ING price would be only $20+.
But, IF (big if) ING can ever return to a normal banking profitability of 1% on assets (Profit/Asset=1.0% as most US banks do today) again, just like ING was well capable to do in 2004-07, with a similar 3-4% dividend,
then ING should make $12.5B profit/year, and at a P/E=11 valuation this adds up to MarketCap=$137.0B; which means ING is priced (137B/3.8B) at $37/share.
This is a longterm, best-case target price; and to achive it again, ING needs a lot to do; like fire the current management and bring in quality guys, replace the Board of Directors, reorganize operations and cut loss centers, focus and motivate employees on profit and not on undeserved perks, etc.
Its a long way to Tipperary: "But try to make it happen Try to fight it out Just stick around, You're down for the final count Get down Get down..."