RULE 22C-2 AGREEMENT

Exhibit 99-B.8.109

RULE 22C-2 AGREEMENT

This AGREEMENT, dated April 16, 2007, is effective as of the 16th day of October, 2007, between
RiverSource Service Corporation (the “Fund”) as transfer agent for each of the RiverSource Funds (the
“RiverSource 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 Funds are available through the variable annuity, variable life insurance and variable
retirement products which the Intermediaries offer (individually, a “Variable Product” and collectively
the “Variable Products”), 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 Provide Shareholder Information.
		1.		Each Intermediary agrees to provide the Fund, upon request, the following
shareholder information involving the Funds:
				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;
				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 otherwise specifically requested by the Fund or its designee, the Intermediaries shall
only be required to provide information relating to Shareholder-Initiated Transfer Purchases or
Shareholder-Initiated Transfer Redemptions.

3. Requests to provide shareholder information shall set forth the specific period for which
transaction information is sought. The Fund may request information daily or for each day during the
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.

4. Each Intermediary agrees to provide the requested shareholder information promptly
upon receipt of the request, but in no event later than 15 business days after receipt of such request,
provided that such information resides in its books and records, via a method mutually agreed upon by

the parties hereto, and the format for any shareholder information provided to the Fund should be
consistent with the NSCC Standardized Data Reporting Format. If shareholder information is not on the
Intermediary’s books and records, the Intermediary agrees to use reasonable efforts to obtain and
transmit or have transmitted the requested information from the holder of the account.

B.		Agreement to Restrict Trading.
		1.		Each Intermediary agrees to execute written instructions from Fund to restrict or prohibit
further purchase or exchanges 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 may violate the policies and procedures established by the Funds for the purposes
of eliminating or reducing frequent trading of Fund shares or which may otherwise constitute excessive
or abusive trading. Unless otherwise directed by the Fund, any such restrictions or prohibitions shall
only apply to Shareholder-Initiated Transfer Purchases.
		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 to restrict or
prohibit trading as soon as reasonably practicable, but no later than 10 Business Days 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 been executed but not later than 10 business
days, after the instructions have been executed.
		2.b		For those Shareholders whose information is not on 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, but no later than 10 Business Days 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 purchases or exchanges 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) and the applicable sections of the Fund’s frequent trading policy
						and procedures;
				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 Fund, that may
						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)

The Fund agrees to reimburse the Intermediaries for reasonable costs they incur that are associated with
complying with extraordinary requests (e.g., transaction information older than 366 days as specified
under Section A) or non-routine purchase restrictions such as blocking new money through payroll/ACH
deposits.

C. Limitation on Use of Information.

The Fund agrees neither to use the information received from the Intermediary for any purpose other
than to comply SEC Rule 22c-2 and other applicable laws, rules and regulations, nor to share the
information with anyone other than its employees, agents, affiliates, Board of Directors, auditors or
regulators 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.

If a party to this Agreement becomes aware of any actual or suspected unauthorized access to or
unauthorized use or disclosure to an unauthorized third party of any non-public personal financial
information of a consumer provided or received pursuant to this Agreement and determines that there is
a reasonable likelihood of harm resulting from such access, use or disclosure, such party promptly shall,
at its expense: (i) notify the other party; (ii) investigate the circumstances relating to such actual or
suspected unauthorized access, use or disclosure; (iii) take commercially reasonable steps to mitigate the
effects of such unauthorized access, use or disclosure and to prevent any reoccurrence; (iv) provide to
the other such information regarding such unauthorized access, use or disclosure as is reasonably
required for the other party to evaluate the likely consequences and any regulatory or legal requirements
arising out of such unauthorized access, use or disclosure; and (v) cooperate with the other party to
further comply with all relevant laws, rules and regulations. The party to this Agreement that causes the
unauthorized access, use or disclosure of such information shall indemnify and hold the other party, (and
any of its directors, officers, employees, or agents) harmless from any damages, loss, cost, or liability
(including reasonable legal fees) arising in connection with a third party claim or action brought against
the other party resulting from such unauthorized use, access or disclosure of the information provided or
received pursuant to this Agreement.
In the event that the Fund is required by legal process, law, or regulation to disclose any information
received from the Intermediaries pursuant to this Agreement to individuals not otherwise authorized in
this Agreement to receive the information, the Fund shall provide Intermediaries with prompt written
notice of such requirement as far in advance of the proposed disclosure as administratively feasible so
that the Intermediaries (at their expense) may either seek a protective order or other appropriate remedy
which is necessary to protect their interests or waive compliance with this provision to the extent
necessary.

D. 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 selling and service agreements.

E.		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: 000 Xxxxxxxxxx Xxxxxx
								Xxxxxxxx, XX 00000-0000
						Phone:		000-000-0000
						Fax:		000-000-0000
						E-mail:		Xxxxxxxxxx.Xxxxxxx@xx.xxx.xxx
				b.		If to the Fund Agent, to:
						RiverSource Funds
						Attention: Mutual Funds Operations and Compliance, 22c-2 Enforcement
						Address: 0000 Xxxxxxxxxx Xxxxxxxxx Xxxxxx
								Xxxxxxxxxxx, XX 00000
						Phone:		(000) 000-0000
						Fax:		(000) 000-0000
						Email:		xxxxxxxxxxx00x0@xxxx.xxx
				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.
F.		Definitions. For purposes of this Agreement:
		(1) The term “Fund” includes the fund’s principal underwriter and transfer agent. The term not
does include any “expected funds” as defined in Rule 22c-2(b).

          (2) The term “Shares” means the interests of Shareholders corresponding to the redeemable
securities of record issued by the Fund under the Investment Company Act of 1940 that are held by
Intermediary.

          (3) The term “Shareholder” means Holder of interests in a variable annuity, variable life
insurance and variable retirement plan products (the “Variable Product”) or participant in an employee
benefit plan with a beneficial interest in a Variable Product.

          (4) The term “Shareholder-Initiated Transfer Purchase” means a transaction that is initiated or
directed by an owner of a Variable Product that results in a transfer of assets within a Variable Product
to a Fund, but does not include transactions that are executed: (i) automatically pursuant to a contractual
or systematic program or enrollment such as transfer of assets within a Variable Product to a Fund as a
result of “dollar cost averaging” programs, insurance company approved asset allocation programs, or
automatic rebalancing programs; (ii) pursuant to a Variable Product death benefit; (iii) one-time step-up
in contract value pursuant to a Variable Product death benefit; (iv) allocation of assets to a Fund through
a Variable Product as a result of payments such as loan repayments, scheduled contributions, retirement
plan salary reduction contributions, or premium payments to the Variable Product; or (v) pre-arranged
transfers at the conclusion of a required free look period.

           (5) The term “Shareholder-Initiated Transfer Redemption” means a transaction that is initiated or
directed by an owner of a Variable Product that results in a transfer of assets within a Variable Product
out of a Fund, but does but does not include transactions that are executed: (i) automatically pursuant to
a contractual or systematic program or enrollment such as transfer of assets within a Variable Product
out of a Fund as a result of annuity payouts, loans, systematic withdrawal programs, “dollar cost
averaging” programs, insurance company approved asset allocation programs, or automatic rebalancing
programs; (ii) as a result of any deduction of charges or fess under a Variable Product; (iii) within a
Variable Product out of a Fund as a result of scheduled withdrawals or surrenders from a Variable
Product; (iv) as a result of payment of a death benefit from a Variable Product.

(5) The term “written” includes electronic writing and facsimile transmissions.

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				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 National Trust				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 USA Annuity and Life Insurance Company				RiverSource Service Corporation
By:		/s/ Xxxxxxxxxx Xxxxxxx		By:		/s/ Xxxxxxxx Xxxxxxx-Strong
Name		Xxxxxxxxxx Xxxxxxx		Name		Xxxxxxxx Xxxxxxx-Strong
and Title:		Authorized Representative		and Title:		President
ReliaStar Life Insurance Company
By:		/s/ Xxxxxxxxxx Xxxxxxx
Name		Xxxxxxxxxx Xxxxxxx
and Title:		Authorized Representative
ReliaStar Life Insurance Company of New York
By:		/s/ Xxxxxxxxxx Xxxxxxx
Name		Xxxxxxxxxx Xxxxxxx
and Title:		Authorized Representative