2007, between Calvert Distributors, Inc. (the “Fund Agent”) as principal underwriter for each of the funds that are the subject of any Current Agreements, (as defined herein) or any future fund participation and/or selling and service agreement (each...

Exhibit 99-B.8.22

RULE 22C-2 AGREEMENT

This AGREEMENT, dated no later than April 16, 2007, is effective as of the 16th day of October,

2007, between Xxxxxxx Distributors, Inc. (the “Fund Agent”) as principal underwriter for each of the

funds that are the subject of any Current Agreements, (as defined herein) or any future fund

participation and/or selling and service agreement (each a “Fund”) 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 A (the “Excessive Trading Policy”);

WHEREAS, the Fund desires 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, the Fund 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 their Variable Products in accordance with the Intermediaries'
Excessive Trading Policy. Said Excessive Trading Policy may be amended from time to time with
the consent of the parties, which consent will not be unreasonably withheld.

2.	The Intermediaries agree to provide the Fund 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.

1.	Each Intermediary agrees to provide the Fund 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, transfers and exchanges; and

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 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. If shareholder
information is not on the Intermediary's books and records, the Intermediary agrees to use best
efforts to determine promptly whether any specific person about whom it has received the
identification and transaction information specified in Section B is itself a financial intermediary
(“indirect intermediary”) and, upon further instruction from the Fund Agent, promptly either (i)
provide or arrange to provide the information set forth in Section B for those shareholders who
hold an account with an indirect intermediary or (ii) restrict or prohibit the indirect intermediary
from purchasing, in nominee name on behalf of other persons, securities issued by the Fund.

C. Agreement to Restrict Trading.

1.	Each Intermediary agrees to execute written instructions from the Fund Agent to
restrict or prohibit further Covered Transactions involving Fund shares by a shareholder who has
been identified by the Fund 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 Intermediary's books and records) the written
instructions within 10 Business Days after actual receipt. The Intermediary will provide written
confirmation to the Fund 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:

	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 the 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 the 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 agrees neither to use the information received from the Intermediary for any purpose

other than to comply with SEC Rule 22c-2 and other applicable laws, rules and regulations, nor to

share the information with anyone other than its employees 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.

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 Agent of any TIN or any

other government issued identifier 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 also agrees that, in the event of any breach or 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 all other remedies available at law or in equity to the Intermediaries.

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, the Fund 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 interests 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 (each such agreement a “Current Agreement”). 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 and/or 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:	000 Xxxxxxxxxx Xxxxxx
		Xxxxxxxx, XX 00000- 0000
	Phone:	000-000-0000
	Fax:	000-000-0000
	Email:	Xxxxxxxxxx.Xxxxxxx@xx.xxx.xxx

b.	If to the Fund Agent, to:
	Xxxxxxx Distributors, Inc.
	Attention: Rule 22c-2
	Address:	0000 Xxxxxxxxxx Xxxxxx, Xxxxx 0000X
Xxxxxxxx, XX 00000
	Phone:	000-000-0000
	Fax:	000-000-0000

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.

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		Xxxxxxx Distributors, Inc.
Company
By:	/s/ Xxxxxxxxxx Xxxxxxx	By:	/s/ Xxxxxxx X. Tantikeff
Name	Xxxxxxxxxx Xxxxxxx	Name	Xxxxxxx X. Tantikeff
and Title:	Authorized Representative	and Title:	General Vice 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

Schedule A
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 identify 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 may 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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2007, between Calvert Distributors, Inc. (the “Fund Agent”) as principal underwriter for each of the funds that are the subject of any Current Agreements, (as defined herein) or any future fund participation and/or selling and service agreement (each...

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