0001193125-09-094534 Sample Contracts

TRANSFER AGENCY SERVICES AGREEMENT
Transfer Agency Services Agreement • April 30th, 2009 • Ing Variable Funds

THIS AGREEMENT (“Agreement”) is dated February 25, 2009 by and between PNC GLOBAL INVESTMENT SERVICING (U.S.) INC., a Massachusetts corporation (“PNC”), and each of the registered investment companies (each, a “Fund”) on behalf of all series thereof (each, a “Portfolio”) listed on Exhibit A attached hereto and made a part hereof.

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May 1, 2009 Ms. Mary Jean Milner Vice President The Bank of New York Mellon
Custody Agreement • April 30th, 2009 • Ing Variable Funds

Pursuant to the terms and conditions of the Custody Agreement, Foreign Custody Manager Agreement, Fund Accounting Agreement, Custody & Fund Accounting Fee Schedule, and Global Securities Fee Schedule, each dated January 6, 2003, and the Cash Reserve Agreement dated March 31, 2003 (the “Agreements”), we hereby notify you of the addition of ING RussellTM Large Cap Growth Index Portfolio, ING RussellTM Large Cap Value Index Portfolio, ING RussellTM Mid Cap Growth Index Portfolio, and ING Hang Seng Index Portfolio (collectively, the “Portfolios”), each a newly established series of ING Variable Portfolios, Inc., to be included on the Amended Exhibit A to the Agreements as shown. This Amended Exhibit A supersedes the previous Amended Exhibit A dated October 31, 2008.

AMENDED AND RESTATED ADMINISTRATION AGREEMENT
Administration Agreement • April 30th, 2009 • Ing Variable Funds • Delaware

This AGREEMENT made this 1st day of April, 2002, as amended and restated on December 31, 2008, between ING Variable Funds (the “Fund”), a Massachusetts business trust, on behalf of each series of the Fund, set forth on Amended Schedule A hereto (each a “Fund,” collectively, the “Funds”), as such schedule may be amended from time to time to add additional series, and ING Funds Services, LLC (the “Administrator”), a Delaware limited liability company.

May 1, 2009 Ms. Mary Jean Milner Vice President The Bank of New York Mellon
Custody Agreement • April 30th, 2009 • Ing Variable Funds

Pursuant to the terms and conditions of the Custody Agreement, Foreign Custody Manager Agreement, Fund Accounting Agreement, Custody & Fund Accounting Fee Schedule, and Global Securities Fee Schedule, each dated January 6, 2003, and the Cash Reserve Agreement dated March 31, 2003 (the “Agreements”), we hereby notify you of the addition of ING RussellTM Large Cap Growth Index Portfolio, ING RussellTM Large Cap Value Index Portfolio, ING RussellTM Mid Cap Growth Index Portfolio, and ING Hang Seng Index Portfolio (collectively, the “Portfolios”), each a newly established series of ING Variable Portfolios, Inc., to be included on the Amended Exhibit A to the Agreements as shown. This Amended Exhibit A supersedes the previous Amended Exhibit A dated October 31, 2008.

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