This AGREEMENT, dated [no later than April 16, 2007], is effective as of the 16th day of October, 2007, between ___________________(the “Fund”) as principal underwriter for each of the funds listed on the attached Schedule A (the “[________] Funds”)...

Exhibit 99.B.8.84 FORM-OF SAMPLE RULE 22C-2 AGREEMENT
This AGREEMENT, dated [no later than April 16, 2007], is effective as of the 16th day of
October, 2007, between ___________________(the “Fund”) as principal underwriter for each of
the funds 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 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, 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

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						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.		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
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 Fund to restrict
or prohibit further Covered Transactions 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.
		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)s and the applicable sections of the
						Fund’s frequent trading policy and procedures that have been violated;

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		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).
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 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 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.

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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 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:		[151 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:
						Attention: [Name or Title of the 22c-2 Contact Person]
						Address:		[XXXXXXXXXXXXXXXXXXXX]
								[XXXXXXXXXXXXXXXXXXXX]
						Phone:		[XXX-XXX-XXXX]
						Fax:		[XXX-XXX-XXXX]
						Email:		[XXXX.XXXXXXX@XXXX.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:		By:
Name		Name
and Title:		and Title:
ING National Trust		Systematized Benefits Administrators Inc.
By:		By:
Name		Name and
and Title:		Title:
ING USA Annuity and Life Insurance		[Full Legal Name of the “Fund”]
Company
By:		By:
Name		Name
and Title:		and Title:
ReliaStar Life Insurance Company
By:
Name
and Title:
ReliaStar Life Insurance Company of New
York
By:
Name
and Title:

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Schedule A

____________________________(the “Fund”) is principal underwriter for each

series/portfolio of the following funds:

    
        · [List the funds to be covered by this agreement]

A-1

Schedule B

ING “Excessive Trading” Policy

(to be amended)