0000925981-05-000006 Sample Contracts

FORM OF PARTICIPATION AGREEMENT Among ING Variable Insurance Trust and ING INSURANCE COMPANY OF AMERICA AND DIRECTED SERVICES, INC.
Participation Agreement • April 18th, 2005 • Variable Annuity Account I of Ing Insurance Co of America • Massachusetts

THIS AGREEMENT, made and entered into as of this ___ day of ___________, 200__, among ING Insurance Company OF AMERICA (the "Company"), a life insurance company organized under the laws of Connecticut, on its own behalf and on behalf of each separate account of the Company set forth on Schedule A attached hereto, as such Schedule may be amended from time to time (each such account hereinafter referred to as the "Account"), ING VARIABLE INSURANCE TRUST ("Trust") an open-ended management investment company and business trust organized under the laws of the Commonwealth of Massachusetts, and DIRECTED SERVICES, INC. (the "Distributor"), a corporation organized under the laws of the State of New York.

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PARTICIPATION AGREEMENT Among ING INSURANCE COMPANY OF AMERICA, PIMCO Variable Insurance Trust, and PA DISTRIBUTORS LLC
Participation Agreement • April 18th, 2005 • Variable Annuity Account I of Ing Insurance Co of America • Connecticut

ING Insurance Company of America ("ING"), PIMCO Variable Insurance Trust (the "Fund") and PA Distributors LLC (the "Underwriter") hereby agree to an arrangement (the "Agreement") whereby the Fund shall be made available to serve as underlying investment media for Variable Annuity or Variable Life Contracts ("Contracts") to be issued by ING.

PIMCO VARIABLE INSURANCE TRUST SERVICES AGREEMENT
Services Agreement • April 18th, 2005 • Variable Annuity Account I of Ing Insurance Co of America • California

This Agreement is made as of May 1, 2004 between PIMCO Variable Insurance Trust (the "Trust") and ING Insurance Company of America ("Authorized Firm").

SERVICES AGREEMENT
Services Agreement • April 18th, 2005 • Variable Annuity Account I of Ing Insurance Co of America

The terms and conditions of this Services Agreement between Pacific Investment Management Company LLC ("PIMCO") and ING Insurance Company of America ("Company") are effective as of May 1, 2004.

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