AMENDMENT NO. 3 TO SELLING AND SERVICES AGREEMENT

                                                                       Exhibit 99-B.8.13

                          AMENDMENT NO. 3 TO SELLING AND SERVICES AGREEMENT

THIS AMENDMENT NO. 3 TO SELLING AND SERVICES AGREEMENT (“Amendment”)
dated this 1st day of April, 2007, is by and among ING FINANCIAL ADVISERS, LLC (formerly known
as Aetna Investment Services, Inc.) and ING LIFE INSURANCE AND ANNUITY COMPANY
(formerly known as Aetna Life Insurance and Annuity Company) (“ILIAC”) (collectively the “ING”),
AMERICAN CENTURY INVESTMENT SERVICES, INC. (“Distributor”) and AMERICAN
CENTURY SERVICES, LLC (formerly known as American Century Services Corporation) (“Fund
Agent”). Capitalized terms not otherwise defined herein shall have the meaning ascribed to them in the
Agreement (defined below).

WHEREAS, ING, Distributor and Fund Agent are parties to a certain Selling and Services
Agreement dated July 1, 2000, as amended November 7, 2003 and October 1, 2004 (the “Agreement”),
pursuant to which shares of the Funds are made available to serve as underlying investment media for
various sponsors of qualified and nonqualified employee benefit plans (the “Plans”), to provide
recordkeeping and related administrative services on behalf of such Plans;

WHEREAS, the parties desire to expand the number of classes of Funds available under the
Agreement, revise the reimbursement terms for such Funds as set forth herein, and make other changes to
the Agreement as set forth herein;

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:

1. Servicing Fees and 12b-1 Fees. The following information is hereby added at the end of
Section 5 and Section 6 of the Agreement.

Effective October 1, 2007, the above referenced address is changed to the following:

ING Financial Advisors, LLC

Attn: Central Valuation ▇▇▇▇

▇▇▇ ▇▇▇▇▇▇ ▇▇▇

▇▇▇▇▇▇▇, ▇▇ ▇▇▇▇▇-▇▇▇▇

2. Miscellaneous. In Section 15(b) Notices of the Agreement, the reference to “AISI/ALIAC” and 

address information is deleted and replaced with following: 

         To ING: 

Effective November 2, 2007, the above referenced information is changed to the 

following: 

▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇

ING

▇▇▇ ▇▇▇▇▇▇ ▇▇▇, ▇▇▇

▇▇▇▇▇▇▇, ▇▇ ▇▇▇▇▇-▇▇▇▇

3. Miscellaneous. Section 15(h) of the Agreement is hereby deleted and replaced with the
following:

(h)      Anti-Money Laundering Provision. Each of the parties to this Agreement will establish and maintain programs, policies and procedures as required by federal, state or local law to detect and prevent money laundering. Each party shall cooperate with the others to the extent required by law to facilitate implementation of each other’s anti-money laundering (AML) program, which may include annual AML compliance certifications, periodic AML due diligence reviews and/or other requests deemed necessary to ensure compliance with the AML regulations.

5. Restrictions on “Excessive Trading.” The following section is hereby added to Section 15,
Miscellaneous, as subsection (i).

(i)

Restrictions on “Excessive Trading.” The Company has adopted its own excessive trading policy, a copy of which is attached as Exhibit C (“Market Timing Policy”).

The Company does not monitor trading in fund shares on behalf of, or in accordance with disclosed policies of, any fund groups; however, the Company monitors individual Participant and contract owner trading in accordance with its Market Timing Policy. The Company will use its best efforts, and shall reasonably cooperate with the Distributor and the Funds, to enforce both its Market Timing Policy and stated policies in a Fund’s currently effective Prospectus or Statement of Additional Information regarding transactions in Fund shares, including those related to market timing and excessive trading. The Company will execute any instructions from the Distributor or the Funds to restrict or prohibit further purchases or exchanges of Fund shares by an individual participant or contract owner who has been identified by the Funds as having engaged in transactions in Fund shares that violate market timing policies established by the Funds. The parties shall use their best efforts, and shall reasonably cooperate with each other to prevent future market timing and frequent trading.

6. Fees Payable to the Company. Schedule B is hereby deleted in its entirety and is
replaced by the attached Schedule B.

7. Ratification and Confirmation of Agreement. In the event of a conflict between the terms of
this Amendment and the Agreement, it is the intention of the parties that the terms of this
Amendment shall control and the Agreement shall be interpreted on that basis. To the extent the
provisions of the Agreement have not been amended by this Amendment, the parties hereby
confirm and ratify the Agreement.

8. Counterparts. This Amendment may be executed in two or more counterparts, each of which
shall be an original and all of which together shall constitute one instrument.

9. Full Force and Effect. Except as expressly supplemented, amended or consented to hereby, all
of the representations, warranties, terms, covenants and conditions of the Agreement shall remain
unamended and shall continue to be in full force and effect.

                                                               2

IN WITNESS WHEREOF, the undersigned have executed this Amendment No. 3 as of the date first
above written.

ING FINANCIAL ADVISERS, LLC				AMERICAN CENTURY INVESTMENT
				SERVICES, INC.
By:		/s/ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇		By:		/s/ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇
Name:		▇▇▇▇▇ ▇. ▇▇▇▇▇▇		Name:		▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇
Title:		V.P. B D Operations		Title:		Vice President
ING LIFE INSURANCE AND				AMERICAN CENTURY SERVICES, LLC
ANNUITY COMPANY
By:		/s/ ▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇		By:		/s/ ▇▇▇▇ ▇. ▇▇▇▇▇
Name:		▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇		Name:		▇▇▇▇ ▇. ▇▇▇▇▇
Title:		Vice President		Title:		Vice President

                                                                       3

                                                                                      SCHEDULE B

                                                FUNDS AVAILABLE AND FEES PAYABLE TO THE COMPANY

Servicing Fees
Distributor agrees to pay the Company a servicing fee as provided in the following table.

Fund Name		Share Class		CUSIP		Symbol		Administrative
								Services Fee Rate
								(Basis Points)
American Century Balanced		Advisor		025083 71 8		TWBAX
American Century Balanced		Institutional		025083 73 4		ABINX
American Century Balanced		Investor		025083 74 2		TWBIX
American Century Capital Growth		A		025083 16 3		ACCGX
American Century Capital Growth		Institutional		02508H 30 3		APLIX
American Century Capital Growth		Investor		02508H 20 4		ACLIX
American Century Capital Growth		R		02508H 40 2		APWRX
American Century Capital Preservation		Investor		025081 80 3		CPFXX
American Century Capital Value		Advisor		025083 42 9		ACCVX
American Century Capital Value		Institutional		025083 41 1		ACPIX
American Century Capital Value		Investor		025083 39 5		ACTIX
American Century Core Plus		A		024932543		ACCQX
American Century Core Plus		Institutional		024932485		ACCUX
American Century Core Plus		Investor		024932493		ACCNX
American Century Core Plus		R		024932519		ACCPX
American Century Disciplined Growth		Advisor		02507M 6 42		ADCVX
American Century Disciplined Growth		Institutional		▇▇▇▇▇▇▇▇▇		ADCIX
American Century Disciplined Growth		R		02507M 65 9		ADRRX
American Century Disciplined Growth		Investor		02507M 67 5		ADSIX
American Century Diversified Bond		A		024932 84 0		CDBAX
American Century Diversified Bond		Advisor		024932 50 1		ADFAX
American Century Diversified Bond		Institutional		024932 60 0		ACBPX
American Century Diversified Bond		Investor		024932 40 2		ADFIX
American Century Diversified Bond		R		024932 71 7		ADVRX
American Century Emerging Markets		Advisor		025086 85 1		AEMMX
American Century Emerging Markets		Institutional		025086 87 7		AMKIX
American Century Emerging Markets		Investor		025086 88 5		TWMIX
American Century Equity Growth		Advisor		02507M 70 9		BEQAX
American Century Equity Growth		Institutional		▇▇▇▇▇▇▇▇▇		AMEIX
American Century Equity Growth		Investor		02507M 60 0		BEQGX
American Century Equity Growth		R		02507M 76 6		AEYRX
American Century Equity Income		Advisor		025076 40 7		TWEAX

                                                                                 4

Fund Name		Share Class		CUSIP		Symbol		Administrative
								Services Fee Rate
								(Basis Points)
American Century Equity Income		Institutional		025076 20 9		ACIIX
American Century Equity Income		Investor		025076 10 0		TWEIX
American Century Equity Income		R		025076 67 0		AEURX
American Century Equity Index		Institutional		025076829		ACQIX
American Century Equity Index		Investor		025076811		ACIVX
American Century Focused Growth		Investor		02508H 10 5		AFSIX
American Century Fundamental Equity		A		025083 13 0		AFDAX
American Century Fundamental Equity		Institutional		02508H 70 9		AFEIX
American Century Fundamental Equity		Investor		02508H 60 0		AFDIX
American Century Fundamental Equity		R		02508H 80 8		AFDRX
American Century ▇▇▇▇▇▇ Mae		Advisor		025081 83 7		BGNAX
American Century ▇▇▇▇▇▇ ▇▇▇		Investor		025081 60 5		BGNMX
American Century Global Gold		Advisor		02507M 20 4		ACGGX
American Century Global Gold		Investor		02507M 10 5		BGEIX
American Century Global Growth		A		025086612		ACWAX
American Century Global Growth		Advisor		025086 82 8		AGGRX
American Century Global Growth		Institutional		025086 83 6		AGGIX
American Century Global Growth		Investor		025086 84 4		TWGGX
American Century Global Growth		R		025086 62 0		AGORX
American Century Government Agency Money		Investor		025081407		BGAXX
Market
American Century Government Bond		Advisor		025081 86 0		ABTAX
American Century Government Bond		Investor		025081 30 8		CPTNX
American Century Growth		Advisor		025083 40 3		TCRAX
American Century Growth		Institutional		025083 20 5		TWGIX
American Century Growth		Investor		025083 10 6		TWCGX
American Century Growth		R		025083 18 9		AGWRX
American Century Heritage		Advisor		025083 76 7		ATHAX
American Century Heritage		Institutional		025083 78 3		ATHIX
American Century Heritage		Investor		025083 79 1		TWHIX
American Century High-Yield		A		024932 81 6		ACYAX
American Century High-Yield		Advisor		024932 88 1		AHYVX
American Century High-Yield		Institutional		024932 78 2		ACYIX
American Century High-Yield		Investor		024932 80 8		ABHIX
American Century High-Yield		R		024932 69 1		AHYRX
American Century Income & Growth		Advisor		02507M 40 2		AMADX
American Century Income & Growth		Institutional		02507M 50 1		AMGIX
American Century Income & Growth		Investor		02507M 30 3		BIGRX
American Century Income & Growth		R		02507M 78 2		AICRX

5

Fund Name		Share Class		CUSIP		Symbol		Administrative
								Services Fee Rate
								(Basis Points)
American Century Inflation Protection Bond		A		024932 75 8		APOAX
American Century Inflation Protection Bond		Institutional		024932 76 6		APISX
American Century Inflation Protection Bond		Investor		024932 77 4		APOIX
American Century Inflation Protection Bond		R		024932 72 5		APORX
American Century Inflation-Adjusted Bond		Advisor		025081 82 9		AIAVX
American Century Inflation-Adjusted Bond		Institutional		025081 79 5		AIANX
American Century Inflation-Adjusted Bond		Investor		025081 70 4		ACITX
American Century International Bond		Advisor		025082 20 7		AIBDX
American Century International Bond		Institutional		025082 30 6		AIDIX
American Century International Bond		Investor		025082 10 8		BEGBX
American Century International Core Equity		A		▇▇▇▇▇▇▇▇▇		ACIQX
American Century International Core Equity		Institutional		▇▇▇▇▇▇▇▇▇		ACIUX
American Century International Core Equity		Investor		▇▇▇▇▇▇▇▇▇		ACIMX
American Century International Core Equity		R		▇▇▇▇▇▇▇▇▇		ACIRX
American Century International Discovery		Advisor		025086802		ACIDX
American Century International Discovery		Institutional		025086 60 4		TIDIX
American Century International Discovery		Investor		025086 50 5		TWEGX
American Century International Growth		A		025086 66 1		CAIGX
American Century International Growth		Advisor		025086 40 6		TWGAX
American Century International Growth		Institutional		025086 20 8		TGRIX
American Century International Growth		Investor		025086 10 9		TWIEX
American Century International Growth		R		025086 64 6		ATGRX
American Century International Stock		Investor		025086 63 8		ASKIX
American Century International Value		Institutional		025086 57 0		ACVUX
American Century International Value		Investor		025086 58 8		ACEVX
American Century International Value		R		025086 53 9		ACVRX
American Century International Value		A		025086 56 2		MEQAX
American Century Large Company Value		A		025076 69 6		ALAVX
American Century Large Company Value		Advisor		025076 78 7		ALPAX
American Century Large Company Value		Institutional		025076 77 9		ALVSX
American Century Large Company Value		Investor		025076 79 5		ALVIX
American Century Large Company Value		R		025076 66 2		ALVRX
American Century Legacy Focused Large Cap		Advisor		▇▇▇▇▇▇▇▇▇		ACFDX
American Century Legacy Focused Large Cap		Institutional		▇▇▇▇▇▇▇▇▇		ACFSX
American Century Legacy Focused Large Cap		Investor		▇▇▇▇▇▇▇▇▇		ACFOX
American Century Legacy Focused Large Cap		R		▇▇▇▇▇▇▇▇▇		ACFCX
American Century Legacy Large Cap		Advisor		▇▇▇▇▇▇▇▇▇		ACGDX
American Century Legacy Large Cap		Institutional		▇▇▇▇▇▇▇▇▇		ACGHX

                                                                              6

Fund Name		Share Class		CUSIP		Symbol		Administrative
								Services Fee Rate
								(Basis Points)
American Century Legacy Large Cap		R		▇▇▇▇▇▇▇▇▇		ACGEX
American Century Legacy Multi Cap		Advisor		▇▇▇▇▇▇▇▇▇		ACMFX
American Century Legacy Multi Cap		Institutional		▇▇▇▇▇▇▇▇▇		ACMHX
American Century Legacy Multi Cap		Investor		▇▇▇▇▇▇▇▇▇		ACMNX
American Century Legacy Multi Cap		R		▇▇▇▇▇▇▇▇▇		ACMEX
American Century Life Sciences		Advisor		025086 79 4		ALSVX
American Century Life Sciences		Investor		025086 81 0		ALSIX
American Century LIVEStrong 2015 Portfolio		Advisor		02507F 20 9		ARFAX
American Century LIVEStrong 2015 Portfolio		Institutional		02507F 30 8		ARNIX
American Century LIVEStrong 2015 Portfolio		Investor		02507F 10 0		ARFIX
American Century LIVEStrong 2015 Portfolio		R		02507F 40 7		ARFRX
American Century LIVEStrong 2025 Portfolio		Advisor		02507F 60 5		ARWAX
American Century LIVEStrong 2025 Portfolio		Institutional		02507F 70 4		ARWFX
American Century LIVEStrong 2025 Portfolio		Investor		02507F 50 6		ARWIX
American Century LIVEStrong 2025 Portfolio		R		02507F 80 3		ARWRX
American Century LIVEStrong 2035 Portfolio		Advisor		02507F 87 8		ARYAX
American Century LIVEStrong 2035 Portfolio		Institutional		02507F 86 0		ARLIX
American Century LIVEStrong 2035 Portfolio		Investor		02507F 88 6		ARYIX
American Century LIVEStrong 2035 Portfolio		R		02507F 85 2		ARYRX
American Century LIVEStrong 2045 Portfolio		Advisor		02507F 83 7		AROAX
American Century LIVEStrong 2045 Portfolio		Institutional		02507F 82 9		AOOIX
American Century LIVEStrong 2045 Portfolio		Investor		02507F 84 5		AROIX
American Century LIVEStrong 2045 Portfolio		R		02507F 81 1		ARORX
American Century LIVEStrong Income Portfolio		Advisor		02507F 78 7		ARTAX
American Century LIVEStrong Income Portfolio		Institutional		02507F 77 9		▇▇▇▇▇
American Century LIVEStrong Income Portfolio		Investor		02507F 79 5		ARTOX
American Century LIVEStrong Income Portfolio		R		02507F 76 1		ARSRX
American Century Long Short Equity		A		▇▇▇▇▇▇▇▇▇		ALIAX
American Century Long Short Equity		Institutional		▇▇▇▇▇▇▇▇▇		ALISX
American Century Long Short Equity		Investor		▇▇▇▇▇▇▇▇▇		ALHIX
American Century Long Short Equity		R		▇▇▇▇▇▇▇▇▇		ALIRX
American Century Mid Cap Value		Advisor		025076 63 9		ACLAX
American Century Mid Cap Value		Institutional		025076 64 7		AVUAX
American Century Mid Cap Value		Investor		025076 65 4		ACMVX
American Century Mid Cap Value		R		025076 61 3		AMVRX
American Century New Opportunities		Investor		025083452		TWNOX
American Century New Opportunities II		A		025083 22 1		ANOAX

                                                                                     7

Fund Name		Share Class		CUSIP		Symbol		Administrative
								Services Fee Rate
								(Basis Points)
American Century New Opportunities II		Institutional		025083 32 0		ANONX
American Century New Opportunities II		Investor		025083 33 8		ANOIX
American Century ▇▇▇▇▇▇		Investor		025085812		AEVIX
American Century One Choice Portfolio:		Investor		▇▇▇▇▇▇▇▇▇		AOGIX
Aggressive
American Century One Choice Portfolio:		Investor		▇▇▇▇▇▇▇▇▇		AOCIX
Conservative
American Century One Choice Portfolio:		Investor		▇▇▇▇▇▇▇▇▇		AOMIX
Moderate
American Century One Choice Portfolio: Very		Investor		▇▇▇▇▇▇▇▇▇		AONIX
Conservative
American Century One Choice Portfolio: Very		Investor		▇▇▇▇▇▇▇▇▇		AOVIX
Aggressive
American Century Premium Money Market		Investor		024932 70 9		TCRXX
American Century Prime Money Market		A		024932 86 5		APMXX
American Century Prime Money Market		Investor		024932 10 5		BPRXX
American Century Real Estate		Advisor		025076 86 0		AREEX
American Century Real Estate		Institutional		025076 87 8		REAIX
American Century Real Estate		Investor		025076 88 6		REACX
American Century Select		A		025083 25 4		AASLX
American Century Select		Advisor		025083 80 9		TWCAX
American Century Select		Institutional		025083 60 1		TWSIX
American Century Select		Investor		025083 50 2		TWCIX
American Century Select		R		02508H 50 1		ASERX
American Century Short Duration Bond		A		024932477		ACSQX
American Century Short Duration Bond		Institutional		024932428		ACSUX
American Century Short Duration Bond		Investor		024932436		ACSNX
American Century Short Duration Bond		R		024932444		ACSPX
American Century Short-Term Government		Advisor		025081 84 5		TWAVX
American Century Short-Term Government		Investor		025081 50 6		TWUSX
American Century Small Cap Value		Advisor		025076 83 7		ACSCX
American Century Small Cap Value		Investor		025076 85 2		ASVIX
American Century Small Cap Value		Institutional		025076845		ACVIX
American Century Small Company		Advisor		02507M 82 4		ASQAX
American Century Small Company		Investor		02507M 84 0		ASQIX
American Century Small Company		Institutional		▇▇▇▇▇▇▇▇▇		ASCQX
American Century Small Company		R		02507M 77 4		ASCRX
American Century Strategic Allocation:		A		025085 79 6		ALLAX
Aggressive
American Century Strategic Allocation:		Advisor		025085 88 7		ACVAX
Aggressive

8

Fund Name		Share Class		CUSIP		Symbol		Administrative
								Services Fee Rate
								(Basis Points)
American Century Strategic Allocation:		Institutional		025085 85 3		AAAIX
Aggressive
American Century Strategic Allocation:		Investor		025085 70 5		TWSAX
Aggressive
American Century Strategic Allocation:		R		025085 71 3		AAARX
Aggressive
American Century Strategic Allocation:		A		025085 75 4		ACEAX
Conservative
American Century Strategic Allocation:		Advisor		025085 30 9		ACCAX
Conservative
American Century Strategic Allocation:		Institutional		025085 87 9		ACCIX
Conservative
American Century Strategic Allocation:		Investor		025085 10 1		TWSCX
Conservative
American Century Strategic Allocation:		R		025085 72 1		AACRX
Conservative
American Century Strategic Allocation: Moderate		A		025085 77 0		ASMAX
American Century Strategic Allocation: Moderate		Advisor		025085 60 6		ACOAX
American Century Strategic Allocation: Moderate		Institutional		025085 86 1		ASAMX
American Century Strategic Allocation: Moderate		Investor		025085 40 8		TWSMX
American Century Strategic Allocation: Moderate		R		025085 82 0		ASMRX
American Century Target Maturity 2010		Advisor		024935 88 4		ACTRX
American Century Target Maturity 2010		Investor		024935 30 6		BTTNX
American Century Target Maturity 2015		Advisor		024935 87 6		ACTTX
American Century Target Maturity 2015		Investor		024935 40 5		BTFTX
American Century Target Maturity 2020		Advisor		024935 86 8		ACTEX
American Century Target Maturity 2020		Investor		024935 50 4		BTTTX
American Century Target Maturity 2025		Advisor		024935 85 0		ACTVX
American Century Target Maturity 2025		Investor		024935 60 3		BTTRX
American Century Technology		Investor		025086 77 8		ATCIX
American Century Ultra		Advisor		025083 85 8		TWUAX
American Century Ultra		Institutional		025083 87 4		TWUIX
American Century Ultra		Investor		025083 88 2		TWCUX
American Century Ultra		R		025083 17 1		AULRX
American Century Utilities		Advisor		02507M 87 3		ACUTX
American Century Utilities		Investor		02507M 88 1		BULIX
American Century Value		A		025076 72 0		ACAVX
American Century Value		Advisor		025076 80 3		TWADX
American Century Value		Institutional		025076 60 5		AVLIX
American Century Value		Investor		025076 50 6		TWVLX
American Century Value		R		025076 62 1		AVURX
American Century Veedot		Institutional		025083346		AVDIX

                                                                                        9

Fund Name		Share Class		CUSIP		Symbol		Administrative
								Services Fee Rate
								(Basis Points)
American Century Veedot		Investor		025083 55 1		AMVIX
American Century Vista		Advisor		025083 81 7		TWVAX
American Century Vista		Institutional		025083 83 3		TWVIX
American Century Vista		Investor		025083841		TWCVX
American Century Vista		R		02508H 88 1		AVTRX
American Century-▇▇▇▇▇ Street High Yield Bond		A		024932 66 7		MHYAX
American Century-▇▇▇▇▇ Street High Yield Bond		Institutional		024932 67 5		ACYSX
American Century-▇▇▇▇▇ Street High Yield Bond		Investor		024932 68 3		ACYVS
American Century-▇▇▇▇▇ Street High Yield Bond		R		024932 63 4		ACYRX
American Century-▇▇▇▇▇ Street Mid Cap Growth		A		02508H 78 2		MAGAX
American Century-▇▇▇▇▇ Street Mid Cap Growth		Institutional		02508H 79 0		ACMIX
American Century-▇▇▇▇▇ Street Mid Cap Growth		Investor		02508H 81 6		ACOVX
American Century-▇▇▇▇▇ Street Mid Cap Growth		R		02508H 75 8		ACMRX
American Century-▇▇▇▇▇ Street Select Bond		A		024932 59 2		MBDAX
American Century-▇▇▇▇▇ Street Select Bond		Institutional		024932 61 8		ACOIX
American Century-▇▇▇▇▇ Street Select Bond		Investor		024932 62 6		ACNVX
American Century-▇▇▇▇▇ Street Select Bond		R		024932 56 8		ACLRX
American Century-▇▇▇▇▇ Street Small Cap		A		02508H 87 5		MSASX
Growth
American Century-▇▇▇▇▇ Street Small Cap		Institutional		02508H 86 5		ACWIX
Growth
American Century-▇▇▇▇▇ Street Small Cap		Investor		02508H 87 3		ACWVX
Growth
American Century-▇▇▇▇▇ Street Small Cap		R		02508H 82 4		ACWRX
Growth

10

                                                    EXHIBIT C - EXCESSIVE TRADING POLICY

Various business units of ING offer variable annuity, variable life insurance and retirement
plan products through which customers may invest directly or indirectly in one or more
mutual funds. Frequent purchases and redemptions of a fund's shares, such as those
associated with "market timing," can adversely affect the fund and the returns achieved by
the fund's share-holders. As a result, many of the funds that are available through ING's
products are taking measures to protect the fund and its shareholders from potentially
harmful trading activity. These measures include reserving the right to reject purchase
requests from shareholders who are making frequent purchases and redemptions of a fund's
shares.
ING, as the provider of multi-fund products, has adopted a definition of "Excessive Trading"
that is intended to respond to a majority of the restrictions on such trading activity that have
been adopted by the various fund families. ING's current definition of Excessive Trading
and our policy with respect to such trading activity is outlined below.
1.		ING currently defines Excessive Trading as more than one purchase and sale of the same
		fund (including money market funds) within a thirty (30) day period. Each fund offered
		through ING's products, either by prospectus or stated policy, has adopted or may adopt
		its own definition of Excessive Trading. Therefore ING reserves the right, without prior
		notice, to modify its general definition or to develop another definition that may apply to
		a particular fund, product or individual, depending on the needs of a particular fund
		and/or state or federal regulatory requirements.
		A purchase followed by one or more sales and then another purchase of the same fund, or
		a sale followed by one or more purchases and then another sale of the same fund would
		meet ING's definition of Excessive Trading. The following transactions are excluded
		when determining whether trading activity is excessive:
		•		Purchases or sales of shares related to non-fund transfers (for example, new
				purchase payments, withdrawals and (loans);
		•		Transfers associated with scheduled dollar cost averaging and scheduled
				rebalancing programs;
		•		Purchases and sales of fund shares in the amount of $250 or less; and
		•		Purchases and sales of funds that affirmatively permit short-term trading in their
				fund shares, and movement between such funds and the money market fund.
2.		ING actively monitors fund transfer and reallocation activity within its products to
		identify Excessive Trading.

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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 that individual a one-time warning letter and place that
		individual on a watch list. According to the needs of the various business units, a copy of
		the warning letter 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.
4.		If ING determines that an individual has used one or more of its products to engage in
		Excessive Trading after having received a warning letter as described above, ING will
		send a second letter to the individual. This letter will state that the individual's ability to
		initiate fund transfers or reallocations through the Internet, facsimile, telephone calls to
		the company's service center, or other electronic trading medium that ING may make
		available from time to time ("Electronic Trading Privileges") has been suspended for a
		period of 6 months. All fund transfers or reallocations will then have to be initiated by
		providing written instructions to ING via regular U.S. mail. During the Suspension
		Period, "inquiry only" privileges will be permitted where and when possible.
5.		Following the 6 month suspension period, the Electronic Trading Privileges may again be
		restored, but ING will continue to monitor the fund transfer and reallocation activity.
		Any future Excessive Trading will result in an indefinite suspension of the Electronic
		Trading Privileges.
6.		ING may elect 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 fall within the
		definition of Excessive Trading set forth above.

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