Contract

                                         Exhibit 99-B.8.38
                FIRST AMENDMENT TO FUND PARTICIPATION AGREEMENT

This Amendment is dated as of May 1, 2007 between Columbia Xxxxxx Asset
Management, LP (the “Adviser”), Xxxxxx Advisors Trust (the “Fund”), ING Life
Insurance and Annuity Company (“ING Life”) and ReliaStar Life Insurance Company
(“ReliaStar”), (collectively, the “parties”).

WHEREAS, the parties entered into a Fund Participation Agreement dated as of May 1,
2004 (the “Agreement”) and now desire to amend the list of Portfolios available set forth
in Schedule B.

WHEREAS, the parties to this Amendment now desire to modify the Agreement as
provided herein.

NOW THEREFORE, in consideration of the mutual promises set forth herein, the parties
hereto agree as follows:

             List of Portfolios Available. Schedule B is hereby deleted in its entirety and is
             replaced by the attached Schedule B.

Aside from the above-referenced amendment, all other terms and conditions of the
Agreement shall remain in full force and effect.

A duly authorized representative of each party has signed this Amendment as of the date
set forth above.

Columbia Xxxxxx Asset Management, XX				Xxxxxx Advisors Trust
	By:	/s/ Xxxxx X. Xxxxx			By:	/s/ Xxxxx X. Xxxxx
	Name:	Xxxxx X. Xxxxx			Name:	Xxxxx X. Xxxxx
	Title:	COO			Title:	Treasurer
ING Life Insurance and Annuity Company				ReliaStar Life Insurance Company
	By:	/s/ Xxxxxxx X. Xxxxxxxx			By:	/s/ Xxxxxx X. Xxxxxx
	Name:	Xxxxxxx X. Xxxxxxxx			Name:	Xxxxxx X. Xxxxxx
	Title:	Vice President			Title:	Vice President

Schedule B

List of Portfolios available

[See Section 1(b) of the Agreement]

Xxxxxx International Small Cap

Xxxxxx Select

Xxxxxx U.S. Smaller Companies