AMENDMENT TO UNDERWRITING AGREEMENT FOR ING PARTNERS, INC. AMENDMENT made as of this 1st day of November, 2004 to the Underwriting Agreement dated as of May 1, 2003, as amended (the "AGREEMENT"), between ING Financial Advisers, LLC and ING Partners,...

                                                             Exhibit (e)(1)(iii)

                                    AMENDMENT
                                       TO
                             UNDERWRITING AGREEMENT
                                       FOR
                               ING PARTNERS, INC.

     AMENDMENT made as of this 1st day of November, 2004 to the Underwriting
Agreement dated as of May 1, 2003, as amended (the "AGREEMENT"), between ING
Financial Advisers, LLC and ING Partners, Inc. In consideration of the mutual
covenants contained herein, the parties agree to amend the Agreement as follows:

1.   SCHEDULE A of the Agreement is hereby deleted and replaced with the AMENDED
SCHEDULE A attached hereto.

2.   In all other respects, the Agreement is confirmed and remains in full force
and effect.

3.   This Amendment shall become effective as of the date first written above.

IN WITNESS WHEREOF, each of the parties has caused this Amendment to be executed
in its name and behalf by its duly authorized representative as of the date set
forth above.


ING FINANCIAL ADVISERS, LLC                   ING PARTNERS, INC.


By:      /s/ Terran X. Xxxxx                  By:     /s/ Xxxxxx X. Xxxxxxxxxxx
         -------------------                          -------------------------
Name:    Terran X. Xxxxx                      Name:   Xxxxxx X. Xxxxxxxxxxx
         ---------------                      Title:  Vice President
Title:   VP, Advisory Services
         ---------------------



                               AMENDED SCHEDULE A

                        Portfolios of ING Partners, Inc.

   ING Aeltus Enhanced Index Portfolio
   ING Xxxxx Aggressive Growth Portfolio
   ING Xxxxx Capital Appreciation Portfolio
   ING Xxxxx Growth Portfolio
   ING American Century Small Cap Value Portfolio
   ING Baron Small Cap Growth Portfolio
   ING Fidelity(R) VIP Contrafund(R)Portfolio
   ING Fidelity(R) VIP Equity Income Portfolio
   ING Fidelity(R) VIP Growth Portfolio
   ING Fidelity(R) VIP Mid Cap Portfolio
   ING Xxxxxxx Xxxxx(R) Capital Growth Portfolio
   ING Xxxxxxx Sachs(R) Core Equity Portfolio
   ING JPMorgan Xxxxxxx International Portfolio
   ING JPMorgan Mid Cap Value Portfolio
   ING MFS Capital Opportunities Portfolio
   ING MFS Global Growth Portfolio
   ING OpCap Balanced Value Portfolio
   ING Xxxxxxxxxxx Strategic Income Portfolio
   ING PIMCO Total Return Portfolio
   ING Salomon Brothers Aggressive Growth Portfolio
   ING Salomon Brothers Fundamental Value Portfolio
   ING Salomon Brothers Investors Value Portfolio
   ING X. Xxxx Price Growth Equity Portfolio
   ING UBS U.S. Allocation Portfolio
   ING UBS U.S. Large Cap Equity Portfolio
   ING Xxx Xxxxxx Xxxxxxxx Portfolio

Dated: November 1, 2004

                                        2