RULE 22C-2 AGREEMENT

Exhibit 99-B.8.10

RULE 22C-2 AGREEMENT

This AGREEMENT, dated April 16, 2007, is to become operational effective as of the 16th day of
October, 2007, between AllianceBernstein Investor Services, Inc. on behalf of each of the
AllianceBernstein Funds (collectively, “Fund” or “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 Funds are available through the variable annuity, variable life insurance and variable
retirement products which the Intermediaries offer (individually, a “Variable Product” and collectively
the “Variable Products”), 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 Provide Shareholder Information.

	1. Each Intermediary agrees to provide the Fund, upon written request, the following
shareholder information 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

		c.		Any other data mutually agreed upon in writing.

2. Unless otherwise specifically requested by the Fund, the Intermediaries shall only be
required to provide information relating to Shareholder-Initiated Transfer Purchases or Shareholder-
Initiated Transfer Redemptions. The term “Shareholder-Initiated Transfer Purchase” means a
transaction that is initiated or directed by an owner of a Variable Product that results in a transfer of
assets within a Variable Product to a Fund, but does not include transactions that are executed: (i)
automatically pursuant to a contractual or systematic program or enrollment such as transfer of assets
within a Variable Product to a Fund as a result of “dollar cost averaging” programs, insurance company
approved asset allocation programs, or automatic rebalancing programs; (ii) pursuant to a Variable
Product death benefit; (iii) one-time step-up in contract value pursuant to a Variable Product death
benefit; (iv) allocation of assets to a Fund through a Variable Product as a result of payments such as

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loan repayments, scheduled contributions, retirement plan salary reduction contributions, or premium
payments to the Variable Product; or (v) pre-arranged transfers at the conclusion of a required free look
period. The term “Shareholder-Initiated Transfer Redemption” means a transaction that is initiated or
directed by an owner of a Variable Product that results in a transfer of assets within a Variable Product
out of a Fund, but does not include transactions that are executed: (i) automatically pursuant to a
contractual or systematic program or enrollments such as transfers of assets within a Variable Product
out of a Fund as a result of annuity payouts, loans, systematic withdrawal programs, “dollar cost
averaging” programs, insurance company approved asset allocation programs, or automatic rebalancing
programs; (ii) as a result of any deduction of charges or fees under a Variable Product; (iii) within a
Variable Product out of a Fund as a result of scheduled withdrawals or surrenders from a Variable
Product; (iv) as a result of payment of a death benefit from a Variable Product.

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 reasonable efforts to obtain and
transmit or have transmitted the requested information from the holder of the account.

B.	Agreement to Restrict Trading.

	1. Each Intermediary agrees to execute written instructions from the Fund to restrict or
prohibit further purchases or exchanges involving Fund shares by a shareholder who has been identified by the Fund 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. Unless otherwise directed by the Fund, any such restrictions or prohibitions shall only apply to Shareholder-Initiated Transfer Purchases.

2a. For those Shareholders whose information is on the Intermediaries’ books and records, the
Intermediaries agree to execute or have executed the written instructions from the Fund to restrict or
prohibit trading as soon as reasonably practicable, but no later than 10 Business Days after receipt of the
instructions by the Intermediaries. The Intermediaries will provide written confirmation to the Fund as
soon as reasonably practicable that such instructions have been executed but not later than 10 business
days after the instructions have been executed.

2b. For those Shareholders whose information is not on the Intermediaries’ books and
records the Intermediaries agree to execute or have executed the written instructions from the Fund to
restrict or prohibit trading as soon as reasonably practicable, but no later than 10 Business Days after
receipt of the instructions by the Intermediaries. The Intermediaries will provide written confirmation to
the Fund as soon as reasonably practicable that such instructions have or have not been executed. If an
indirect intermediary is unable or unwilling to restrict or prohibit trading by a Shareholder, upon the
Funds’ written request, the Intermediary will restrict or prohibit transactions in Fund Shares by the
Indirect Intermediary.

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3. Instructions to restrict or prohibit further purchases or exchanges involving Fund shares
must include:

		a.		A statement from the Fund that the shareholder’s trading activity has either
				violated the Fund’s frequent trading policy or, in the Fund’s sole discretion, such
				trading activity has been deemed disruptive;

		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 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).

The Fund agrees to reimburse the Intermediaries for reasonable costs they incur that are associated with
complying with extraordinary requests (e.g., transaction information older than 366 days as specified
under Section A) or non-routine purchase restrictions such as blocking new money through payroll/ACH
deposits.

C. 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 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 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 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

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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.

D. 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 and/or selling and service agreements.

E. 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, to:
c.
	AllianceBernstein Investor Services, Inc.
	Attention: Legal and Compliance Department

	Address:	1345 Avenue of the Xxxxxxxx, 00^xxXxxxx
Xxx Xxxx, XX 00000
	Phone:	000-000-0000
	Fax:	000-000-0000

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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 and	Xxxxxxxxxx Xxxxxxx	Name	Xxxxxxxxxx Xxxxxxx
Title:	Authorized Representative	and Title:	Authorized Representative

ING National Trust		Systematized Benefits Administrators Inc.

By:	/s/ Xxxxxxxxxx Xxxxxxx	By:	/s/ Xxxxxxxxxx Xxxxxxx

Name and	Xxxxxxxxxx Xxxxxxx	Name and	Xxxxxxxxxx Xxxxxxx
Title:	Authorized Representative	Title:	Authorized Representative

ING USA Annuity and Life Insurance Company		AllianceBernstein Investor Services, Inc.

By:	/s/ Xxxxxxxxxx Xxxxxxx	By:	/s/ Xxxxxx X. Xxxxx

Name and	Xxxxxxxxxx Xxxxxxx	Name	Xxxxxx X. Xxxxx
Title:	Authorized Representative	and Title:	Assistant Secretary

ReliaStar Life Insurance Company

By:	/s/ Xxxxxxxxxx Xxxxxxx

Name and	Xxxxxxxxxx Xxxxxxx
Title:	Authorized Representative

ReliaStar Life Insurance Company of New York

By:	/s/ Xxxxxxxxxx Xxxxxxx

Name and	Xxxxxxxxxx Xxxxxxx
Title:	Authorized Representative

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RULE 22C-2 AGREEMENT

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