RULE 22C-2 AGREEMENT

Exhibit 99-B.8.83

RULE 22C-2 AGREEMENT

This AGREEMENT, dated as of March 27, 2007, is effective as of the 16th day of October,
2007, between IXIS Asset Management Distributors, L.P. (the “Fund Agent” or “IXIS”) as
principal underwriter for each of the fund families listed on the attached Schedule A (the
“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 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”); and

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 B (the “Excessive Trading
Policy”);

WHEREAS, the Funds desire 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, Fund Agent 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 the Intermediaries’ Variable Products in accordance with 

the Intermediaries’ Excessive Trading Policy. Said Excessive Trading Policy may be amended 

from to time to time with the consent of the parties, which consent will not be unreasonably 

withheld. 

                   2. The Intermediaries agree to provide the Funds, Fund Agent or their designated 

agent, with 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 to regular U.S. mail trading under the Intermediaries’ Excessive Trading Policy. 

B. Agreement to Provide Shareholder Information. 

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		1.		Each Intermediary agrees to provide the Fund s, Fund Agent or their designated
		agent, upon written request, the following shareholder information with respect to Covered
		Transactions 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, and exchanges; and
		c.		Any other data mutually agreed upon in writing.
		2.		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.
		3.		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 ninety (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 fifteen (15) business days after
receipt of such request, provided that such information resides in its books and records. 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.
C.		Agreement to Restrict Trading.
		1.		Each Intermediary agrees to execute written instructions from the Funds, Fund
Agent or their designated agent, to restrict or prohibit further Covered Transactions involving
Fund shares by a shareholder who has been identified by the Funds, Fund Agent or their
designated agent, 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.
		2.		Each Intermediary agrees to use reasonable efforts to execute or have executed
(for those shareholders whose information is not on the Intermediaries’ books and records) the
written instructions within ten (10) Business Days after actual receipt. The Intermediary will
provide written confirmation to the Funds, Fund Agent or their designated agent, as soon as
reasonably practicable that such instructions have or have not been executed. If the written
instructions have not been executed, then the written confirmation will also provide an
explanation.
		3.		Instructions to restrict or prohibit further Covered Transactions involving Fund
shares must include:
				2

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		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 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 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)

D. Limitation on Use of Information.

The Fund Agent agrees that the Funds, Fund Agent or their designated agent(s), will use the
information received from the Intermediary only for the purpose of complying with SEC Rule
22c-2 and other applicable laws, rules and regulations, and shall not share the information with
anyone other than employees who legitimately need access to it. Neither the Funds, Fund Agent
or their designated agent, nor any of its affiliates or subsidiaries may use any information
provided pursuant to this Agreement for marketing or solicitation purposes. The Fund Agent
will take such steps as are reasonably necessary to ensure compliance with this obligation.

The Fund Agent shall indemnify and hold the Intermediaries, 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 Fund s, Fund Agent
or their designated agent(s), of the information received from the Intermediaries pursuant to this
Agreement. In addition, because an award of money damages (whether pursuant to the
foregoing sentence or otherwise ) may be inadequate for any breach of this provision and any
such breach may cause the Intermediaries irreparable harm, the Fund Agent also agrees that, in
the event of any breach of threatened breach of this provision, the Intermediaries 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 al other remedies available at
law or in equity to the Intermediaries.

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In the event that the Fund Agent is required by legal process, law or regulation to disclose any
information received from the Intermediaries pursuant to this Agreement, the Fund Agent shall
provide Intermediaries with prompt written notice of such requirement as far in advance of the
proposed disclosure as possible so that the Intermediaries (at their expense) may either seek a
protective order or other appropriate remedy which is necessary to protect their interest or waive
compliance with this provision to the extent necessary.

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 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:		[151 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:
				IXIS Asset Management Distributors, L.P.
				Attention: Xxxx Xxxxx-Xxxxxxxx, VP, Counsel
				Address:		000 Xxxxxxxx Xxxxxx
						Xxxxxx, XX 00000
				Phone:		000-000-0000
				Fax:		000-000-0000
				Email:		xxxxxxxxx@xxxxxx.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.

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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				IXIS Asset Management Distributors, L.P. as
				distributor of the Funds
By:		/s/ Xxxxxxxxxx Xxxxxxx		By:		/s/ Xxxx X. Xxxxxxxxx
Name		Xxxxxxxxxx Xxxxxxx		Name		Xxxx X. Xxxxxxxxx
and Title:		Authorized Representative		and Title:		COO & EVP
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

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Schedule A

IXIS Asset Management Distributors, L.P. is the principal underwriter for each of the
Family of Funds set forth below.

• IXIS Advisor Funds (not available)
• Xxxxxx Xxxxxx Funds
• The Delafield Fund, Inc. (not available)
• Xxxxxxxxxx Funds (not available)

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Schedule B

ING “Excessive Trading” Policy

The ING family of insurance 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 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 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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