INITIAL CAPITAL AGREEMENT
Exhibit (l)(1)
May 16, 2007
c/o ING Funds Distributor, LLC
0000 Xxxx Xxxxxxxxxx Xxxxx Xxxx
Xxxxxxxxxx, XX 00000
Dear Gentlemen:
We understand that ING Separate Portfolios Trust (“ING SPorts”) proposes to sell shares of beneficial interests (the “Shares”) of ING SPorts Core Fixed Income Fund and ING SPorts Core Plus Fixed Income Fund pursuant to a registration statement on Form N-1A filed with the U.S. Securities and Exchange Commission. In order to provide ING SPorts with a net worth of at least $100,000 as required by Section 14 of the Investment Company Act of 1940, as amended, we hereby offer to purchase the number of Shares of each ING SPorts Core Fixed Income Fund at a price per share as indicated below.
| Portfolio |
Number of Shares |
Price per Share | |||
| ING SPorts Core Fixed Income Fund |
10,000 | $ | 10.00 | ||
We represent and warrant to ING SPorts that the Shares are being acquired by us for the purposes of providing seed capital and not with a view to the resale or further distribution thereof and that we have no present intention to redeem or dispose of any such Shares.
Please confirm that the foregoing correctly sets forth our agreement with ING SPorts.
| Sincerely, | ||
| ING Life Insurance and Annuity Company | ||
| By: | /s/ Xxxxxxx X. Xxxxx | |
| Name: | Xxxxxxx X. Xxxxx | |
| Title: | Vice President | |
Confirmed, as of the date first mentioned
| ING Separate Portfolios Trust | ||
| By: | /s/ Xxxx Xxxxx | |
| Name: | Xxxx Xxxxx | |
| Title: | Senior Vice President | |
