This AGREEMENT, made and entered into as of this 13th day of September, 2010, between ALPS Distributors, Inc. (the "Fund") as principal underwriter for each of the funds (the "CRM Funds") and ING Life Insurance and Annuity Company, ING National Trust,...

Exhibit 24(b)(8.30)
RULE 22C-2 AGREEMENT

This AGREEMENT, made and entered into as of this 13th day of September, 2010, between ALPS 

Distributors, Inc. (the "Fund") as principal underwriter for each of the funds (the "CRM Funds") and ING 

Life Insurance and Annuity Company, ING National Trust, ING USA Annuity and Life Insurance 

Company, ReliaStar Life Insurance Company, ReliaStar Life Insurance Company of New York, Security 

Life of Denver Insurance Company and Systematized Benefits Administrators Inc. (individually an 

"Intermediary" and collectively the "Intermediaries") 

WHEREAS, the Fund and the Intermediary have entered into a fund participation and/or selling and 

service agreement dated September 13, 2010; 

WHEREAS, the Intermediaries have adopted policies and procedures to monitor and deter excessive 

trading activity within the mutual funds, including the Funds, available through the variable annuity, 

variable life insurance and variable retirement plan products which they offer (the "Variable Products"); 

WHEREAS, the Intermediaries' policies and procedures to monitor and deter excessive trading activity 

within the mutual funds available through their Variable Products are attached hereto and made part of 

this Agreement as Schedule A (the "Excessive Trading Policy"); 

WHEREAS, the Fund desires for the Intermediaries to monitor and deter excessive trading activity in the 

Funds in accordance with the Intermediaries' Excessive Trading Policy; and 

WHEREAS, the parties desire to otherwise comply with the requirements under Rule 22c-2 of the 

Investment Company Act of 1940, as amended ("Rule 22c-2"). 

NOW, THEREFORE, in consideration of the mutual covenants herein contained, which consideration is 

full and complete, the Fund and the Intermediaries hereby agree as follows: 

A. Agreement to Monitor and Deter Excessive Trading Activity. 

1. The Intermediaries agree to monitor and deter excessive trading activity in the Funds which are 

available through their Variable Products in accordance with the Intermediaries' Excessive Trading 

Policy. Said Excessive Trading Policy may be amended from time to time with the written consent of the 

parties, which consent will not be unreasonably withheld. 

2. The Intermediaries agree to provide the Fund the taxpayer identification number ("TIN"), if 

requested, or any other identifying factor that would provide acceptable assurances of the identity of all 

shareholders that are restricted in the Fund to regular U.S. mail trading under the Intermediaries' 

Excessive Trading Policy. 

B. Agreement to Provide Shareholder Information. 

1. Each Intermediary agrees to provide the Fund, upon written request, the following shareholder 

information: 

a. The taxpayer identification number ("TIN") or any other government issued identifier, if 

known, that would provide acceptable assurances of the identity of each shareholder that has 

purchased, redeemed, transferred or exchanged shares of a Fund through an account directly 

   maintained by the Intermediaries during the period covered by the request; 

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b.	The amount and dates of, and the Variable Product(s) associated with, such shareholder
	purchases, redemptions, transfers and exchanges; and
c.	Any other data mutually agreed upon in writing.
2. Unless specifically requested by the Fund, the Intermediaries shall only be required to provide
information relating to Covered Transactions.
3. Under this Agreement the term "Covered Transactions" are those transactions which the
Intermediaries consider when determining whether trading activity is excessive as described in their
Excessive Trading Policy under paragraph 1 of said Policy.
4. Requests to provide shareholder information shall set forth the specific period for which
transaction information is sought. However, unless otherwise agreed to by the Intermediaries, any such
request will not cover a period of more than 90 consecutive calendar days from the date of the request.
5. The Intermediaries agree to provide, promptly upon request of the Fund the shareholder
information requested. If requested by the Fund, the Intermediaries agree to use best efforts to determine
promptly whether any specific person about whom they have received shareholder information is itself a
financial intermediary ("indirect intermediary") and, upon further request of the Fund, promptly either (i)
provide (or arrange to have provided) shareholder information for those shareholders who hold an account
with an indirect intermediary or (ii) restrict or prohibit the indirect intermediary from purchasing shares,
in nominee name on behalf of other persons, securities issued by a Fund. Responses required by this
paragraph must be communicated in writing and in a format mutually agreed upon by the parties. To the
extent practicable, the format for any Shareholder Information provided to the Fund should be consistent
with the NSCC Standardized Data Reporting Format.
6. The Fund shall cause the CRM Funds to reimburse the Intermediaries for costs that are
reasonable and necessary, and incurred with complying with extraordinary requests (e.g., transaction
information older than one year).
C. Agreement to Restrict Trading.
1. Each Intermediary agrees to execute written instructions from the Fund to restrict or prohibit
further Covered Transactions involving Fund shares by a shareholder who has been identified by the Fund
as having engaged in transactions in shares of a Fund (through an account directly maintained by the
Intermediary) that violate the policies and procedures established by the Funds for the purposes of
eliminating or reducing frequent trading of Fund shares. Unless otherwise directed by the Fund, any such
restrictions or prohibitions only apply to Covered Transactions.
2. a.	For those shareholders whose information is on the Intermediaries' books and records, the
	Intermediaries agree to execute or have executed the written instructions from the Fund or its
	designee to restrict or prohibit trading as soon as reasonably practicable after receipt of the
	instructions by the Intermediaries. The Intermediaries will provide written confirmation to the
Fund as soon as reasonably practicable after the instructions have been executed.
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	b.	For those shareholders whose information is not on the Intermediaries' books and records the
		Intermediaries agree to execute or have executed the written instructions from the Fund to
		restrict or prohibit trading as soon as reasonably practicable after receipt of the instructions
		by the Intermediaries. The Intermediaries will provide written confirmation to the Fund as
		soon as reasonably practicable that such instructions have or have not been executed. If an
		indirect intermediary is unable or unwilling to restrict or prohibit trading by a Shareholder,
		upon the Funds' written request, the Intermediary will restrict or prohibit transactions in Fund
		Shares by the indirect intermediary.
3.	Instructions to restrict or prohibit further Covered Transactions involving Fund shares must
include:
	a.	The reason for requesting the restriction(s) and/or prohibition(s), supporting details regarding
		the transaction activity which resulted in the restriction(s) and/or prohibition(s)s and the
		applicable sections of the Fund's frequent trading policy and procedures that have been
		violated;
	b.	The specific restriction(s) and/or prohibition(s) to be executed, including the length of time
		such restriction(s) and/or prohibition(s) shall remain in place;
	c.	The TIN or any other government issued identifier, if known by the Fund, that would help the
		Intermediaries determine the identity of affected shareholder(s); and
	d.	Whether such restriction(s) and/or prohibition(s) are to be executed in relation to all of the
		affected shareholder's Variable Products, only the type of Variable Product(s) through which
		the affected shareholder engaged in transaction activity which triggered the restriction(s)
		and/or prohibition(s) or in some other respect. In absence of direction from the Fund in this
regard, restriction(s) and/or prohibition(s) shall be executed as they relate to the
		Intermediary's Variable Product(s) through which the affected shareholder engaged in the
		transaction activity which triggered the restriction(s) and/or prohibition(s).
4.	The Fund shall cause the CRM Funds to reimburse the Intermediaries for reasonable transaction
costs they incur directly resulting from requests by the Fund or its designee to implement non-routine
purchase restrictions such as blocking new money through payroll/ACH deposits.
D. Limitation on Use of Information.
The Fund agrees neither to use the information received from the Intermediary for any purpose other than
to comply with SEC Rule 22c-2 and other applicable laws, rules and regulations, nor to share the
information with anyone other than its employees who legitimately need access to it. Neither the Fund nor
any of its affiliates or subsidiaries may use any information provided pursuant to this Agreement for
marketing or solicitation purposes. The Fund will take such steps as are reasonably necessary to ensure
compliance with this obligation.
Each party shall indemnity and hold the other party, individually and collectively, (and any of their
respective directors, officers, employees, or agents) harmless from any damages, loss, cost, or liability
(including reasonable legal fees and the cost of enforcing this indemnity) arising out of or resulting from
any unauthorized use of or disclosure by the breaching party of the information received from the other
parties pursuant to this Agreement. In addition, because an award of money damages (whether pursuant to
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the foregoing sentence or otherwise) may be inadequate for any breach of this provision and any such
breach may cause the non-breaching parties irreparable harm, the party in breach also agrees that, in the
event of any breach or threatened breach of this provision, the non-breaching parties will also be entitled,
without the requirement of posting a bond or other security, to seek equitable relief, including injunctive
relief and specific performance. Such remedies will not be the exclusive remedies for any breach of this
provision but will be in addition to all other remedies available at law or in equity to the non-breaching
parties.
In the event that a party is required by legal process, law, or regulation to disclose any information
received from a non-disclosing party pursuant to this Agreement, the disclosing party shall provide the
non-disclosing parties with written notice of such requirement, when circumstances permit, so that the
non-disclosing party (at its expense) may either seek a protective order or other appropriate remedy which
is necessary to protect its interests.
E. Prior Agreements.
The parties acknowledge that prior to the effective date of this Agreement efforts to monitor and deter
excessive trading activity within the Variable Products were governed by whatever practices the Fund and
the Intermediaries agreed to follow in the absence of any formal agreement. The parties also acknowledge
having previously entered into fund participation and/or selling and service agreements concerning the
purchase and redemption of shares of Funds through the Variable Products. The terms of this Agreement
supplement the fund participation and/or selling and service agreements and to the extent the terms of this
Agreement conflict with the terms of the fund participation and/or selling and service agreements, the
terms of this Agreement will control. This Agreement will terminate upon termination of the fund
participation and/or selling and service agreements.
F. Notices.
1. Except as otherwise provided, all notices and other communications hereunder shall be in writing
and shall be sufficient if delivered by hand or if sent by confirmed facsimile or e-mail, or by mail, postage
prepaid, addressed:
a.	If to Intermediaries, to:
	ING U.S. Financial Services
	Attention:	Xxxxxxxxxx Xxxxxxx
	Address:	Xxx Xxxxxx Xxx
		Xxxxxxx, XX 00000-0000
	Phone:	000-000-0000
	Fax:	000-000-0000
	Email:	Xxxxxxxxxx.Xxxxxxx@xx.xxx.xxx
b.	If to the Fund, to:
	Attention:	Xxxxxx Xxxxxxxx, General Counsel & Chief Compliance Officer
	Address:	000 Xxxxxxx Xxxxxx, 00xx Xxxxx
		Xxx Xxxx, XX 00000
	Phone:	000-000-0000
	Fax:	000-000-0000
	Email:	xxxxxxxxx@xxxxxx.xxx
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2. The parties may by like notice, designate any future or different address to which subsequent
notices shall be sent. Any notice shall be deemed given when received.
IN WITNESS WHEREOF, each of the parties hereto has caused this Agreement to be executed in its
name and on its behalf by its duly authorized officer as of the date first written above.
ING Life Insurance and Annuity Company		Systematized Benefits Administrators Inc.
By:	/s/ Xxxxxxxxxx Xxxxxxx	By:	/s/ Xxxxxxxxxx Xxxxxxx
Name	Xxxxxxxxxx Xxxxxxx	Name	Xxxxxxxxxx Xxxxxxx
and Title:	Authorized Representative	and Title:	Authorized Representative
ING National Trust		Security Life of Denver Insurance Company
By:	/s/ Xxxxxxxxxx Xxxxxxx	By:	/s/ Xxxxxxxxxx Xxxxxxx
Name	Xxxxxxxxxx Xxxxxxx	Name	Xxxxxxxxxx Xxxxxxx
and Title:	Authorized Representative	and Title:	Authorized Representative
ING USA Annuity and Life Insurance		ReliaStar Life Insurance Company of New
Company		York
By:	/s/ Xxxxxxxxxx Xxxxxxx	By:	/s/ Xxxxxxxxxx Xxxxxxx
Name	Xxxxxxxxxx Xxxxxxx	Name	Xxxxxxxxxx Xxxxxxx
and Title:	Authorized Representative	and Title:	Authorized Representative
ReliaStar Life Insurance Company		ALPS Distributors, Inc.
By:	/s/ Xxxxxxxxxx Xxxxxxx	By:	/s/ Xxxx X. Xxxxx
Name	Xxxxxxxxxx Xxxxxxx	Name	Xxxx X. Xxxxx
and Title:	Authorized Representative	and Title:	Secretary
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Schedule A
ING "Excessive Trading" Policy
The ING family of companies ("ING"), as providers of multi-fund variable insurance and retirement
products, has adopted this Excessive Trading Policy to respond to the demands of the various fund
families which make their funds available through our variable insurance and retirement products to
restrict excessive fund trading activity and to ensure compliance with Section 22c-2 of the Investment
Company Act of 1940, as amended. ING's current definition of Excessive Trading and our policy with
respect to such trading activity is outlined below.
1.	ING actively monitors fund transfer and reallocation activity within its variable insurance and
	retirement products to identify Excessive Trading.
	ING currently defines Excessive Trading as:
	a.	More than one purchase and sale of the same fund (including money market funds) within a
		60 calendar day period (hereinafter, a purchase and sale of the same fund is referred to as a
		"round-trip"). This means two or more round-trips involving the same fund within a 60
		calendar day period would meet ING's definition of Excessive Trading; or
	b.	Six round-trips within a twelve month period.
	The following transactions are excluded when determining whether trading activity is excessive:
	a.	Purchases or sales of shares related to non-fund transfers (for example, new purchase
		payments, withdrawals and loans);
	b.	Transfers associated with scheduled dollar cost averaging, scheduled rebalancing or
		scheduled asset allocation programs;
	c.	Purchases and sales of fund shares in the amount of $5,000 or less;
	d.	Purchases and sales of funds that affirmatively permit short-term trading in their fund shares,
		and movement between such funds and a money market fund; and
	e.	Transactions initiated by a member of the ING family of insurance companies.
2.	If ING determines that an individual has made a purchase of a fund within 60 days of a prior round-
	trip involving the same fund, ING will send them a letter warning that another sale of that same fund
	within 60 days of the beginning of the prior round-trip will be deemed to be Excessive Trading and
	result in a six month suspension of their ability to initiate fund transfers or reallocations through the
	Internet, facsimile, Voice Response Unit (VRU), telephone calls to the ING Customer Service Center,
	or other electronic trading medium that ING may make available from time to time ("Electronic
	Trading Privileges"). Likewise, if ING determines that an individual has made five round-trips within
	a twelve month period, ING will send them a letter warning that another purchase and sale of that
	same fund within twelve months of the initial purchase in the first round-trip in the prior twelve
	month period will be deemed to be Excessive Trading and result in a six month suspension of their
	Electronic Trading Privileges. According to the needs of the various business units, a copy of the
	warning letters may also be sent, as applicable, to the person(s) or entity authorized to initiate fund
	transfers or reallocations, the agent/registered representative or investment adviser for that individual.
	A copy of the warning letters and details of the individual's trading activity may also be sent to the
	fund whose shares were involved in the trading activity.
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3.	If ING determines that an individual has used one or more of its products to engage in Excessive
	Trading, ING will send a second letter to the individual. This letter will state that the individual's
	Electronic Trading Privileges have been suspended for a period of six months. Consequently, all fund
	transfers or reallocations, not just those which involve the fund whose shares were involved in the
	Excessive Trading activity, will then have to be initiated by providing written instructions to ING via
	regular U.S. mail. During the six month suspension period, electronic "inquiry only" privileges will
	be permitted where and when possible. A copy of the letter restricting future transfer and reallocation
	activity to regular U.S. mail and details of the individual's trading activity may also be sent to the
	fund whose shares were involved in the Excessive Trading activity.
4.	Following the six month suspension period during which no additional Excessive Trading is
	identified, Electronic Trading Privileges may again be restored. ING will continue to monitor the
	fund transfer and reallocation activity, and any future Excessive Trading will result in an indefinite
	suspension of the Electronic Trading Privileges. Excessive Trading activity during the six month
	suspension period will also result in an indefinite suspension of the Electronic Trading Privileges.
5.	ING reserves the right to limit fund trading or reallocation privileges with respect to any individual,
	with or without prior notice, if ING determines that the individual's trading activity is disruptive,
	regardless of whether the individual's trading activity falls within the definition of Excessive Trading
	set forth above. Also, ING's failure to send or an individual's failure to receive any warning letter or
	other notice contemplated under this Policy will not prevent ING from suspending that individual's
	Electronic Trading Privileges or taking any other action provided for in this Policy.
6.	Each fund available through ING's variable insurance and retirement products, either by prospectus or
	stated policy, has adopted or may adopt its own excessive/frequent trading policy. ING reserves the
	right, without prior notice, to implement restrictions and/or block future purchases of a fund by an
	individual who the fund has identified as violating its excessive/frequent trading policy. All such
	restrictions and/or blocking of future fund purchases will be done in accordance with the directions
	ING receives from the fund.
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