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Excessive Trading

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									ING “EXCESSIVE TRADING” POLICY


The ING family of companies       1. ING actively monitors fund transfer       2. If ING determines that an individual
(“ING”), as providers of multi-      and reallocation activity within its         has made a purchase of a fund
                                     variable insurance and retirement            within 60 days of a prior round-trip
fund variable insurance and          products to identify Excessive               involving the same fund, ING will
retirement products, has             Trading.                                     send them a letter warning that
adopted this Excessive Trading    ING currently defines Excessive
                                                                                  another sale of that same fund
Policy to respond to the                                                          within 60 days of the beginning of
                                  Trading as:
                                                                                  the prior round-trip will be deemed
demands of the various fund          a. More than one purchase and                to be Excessive Trading and result in
families which make their funds         sale of the same fund (including          a six month suspension of their
available through our variable          money market funds) within a 60           ability to initiate fund transfers or
insurance and retirement                calendar day period (hereinafter,         reallocations through the Internet,
                                        a purchase and sale of the same           facsimile, Voice Response Unit
products to restrict excessive          fund is referred to as a “round-          (VRU), telephone calls to the ING
fund trading activity and to            trip”). This means two or more            Customer Service Center, or other
ensure compliance with Section          round-trips involving the same            electronic trading medium that ING
22c-2 of the Investment                 fund within a 60 calendar day             may make available from time to
                                        period would meet ING’s                   time (“Electronic Trading
Company Act of 1940, as                 definition of Excessive Trading; or       Privileges”). Likewise, if ING
amended. ING’s current                                                            determines that an individual has
                                     b. Six round-trips within a twelve
definition of Excessive Trading         month period.
                                                                                  made five round-trips within a
and our policy with respect to                                                    twelve month period, ING will send
                                  The following transactions are                  them a letter warning that another
such trading activity             excluded when determining whether               purchase and sale of that same fund
is outlined below.                trading activity is excessive:                  within twelve months of the initial
                                                                                  purchase in the first round-trip in
                                     a. Purchases or sales of shares
                                                                                  the prior twelve month period will
                                        related to non-fund transfers
                                                                                  be deemed to be Excessive Trading
                                        (for example, new purchase
                                                                                  and result in a six month suspension
                                        payments, withdrawals and
                                                                                  of their Electronic Trading Privileges.
                                        loans);
                                                                                  According to the needs of the
                                     b. Transfers associated with                 various business units, a copy of the
                                        scheduled dollar cost averaging,          warning letters may also be sent, as
                                        scheduled rebalancing or                  applicable, to the person(s) or entity
                                        scheduled asset allocation                authorized to initiate fund transfers
                                        programs;                                 or reallocations, the agent/registered
                                                                                  representative or investment adviser
                                     c. Purchases and sales of fund
                                                                                  for that individual. A copy of the
                                        shares in the amount of $5,000
                                                                                  warning letters and details of the
                                        or less;
                                                                                  individual’s trading activity may also
                                     d. Purchases and sales of funds that         be sent to the fund whose shares
                                        affirmatively permit short-term           were involved in the trading activity.
                                        trading in their fund shares, and
                                        movement between such funds
                                        and a money market fund; and
                                     e. Transactions initiated by a
                                        member of the ING family of
                                        insurance companies.




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ING “EXCESSIVE TRADING” POLICY



3. If ING determines that an individual                    4. Following the six month suspension                        6. Each fund available through ING’s
   has used one or more of its                                period during which no additional                            variable insurance and retirement
   products to engage in Excessive                            Excessive Trading is identified,                             products, either by prospectus or
   Trading, ING will send a second                            Electronic Trading Privileges may                            stated policy, has adopted or may
   letter to the individual. This letter                      again be restored. ING will continue                         adopt its own excessive/frequent
   will state that the individual’s                           to monitor the fund transfer and                             trading policy. ING reserves the
   Electronic Trading Privileges have                         reallocation activity, and any future                        right, without prior notice, to
   been suspended for a period of six                         Excessive Trading will result in an                          implement restrictions and/or block
   months. Consequently, all fund                             indefinite suspension of the                                 future purchases of a fund by an
   transfers or reallocations, not just                       Electronic Trading Privileges.                               individual who the fund has
   those which involve the fund whose                         Excessive Trading activity during                            identified as violating its
   shares were involved in the Excessive                      the six month suspension period                              excessive/frequent trading policy. All
   Trading activity, will then have to be                     will also result in an indefinite                            such restrictions and/or blocking of
   initiated by providing written                             suspension of the Electronic                                 future fund purchases will be done
   instructions to ING via regular U.S.                       Trading Privileges.                                          in accordance with the directions
   mail. During the six month                                                                                              ING receives from the fund.
                                                           5. ING reserves the right to limit fund
   suspension period, electronic
                                                              trading or reallocation privileges
   “inquiry only” privileges will be
                                                              with respect to any individual, with
   permitted where and when possible.
                                                              or without prior notice, if ING
   A copy of the letter restricting future
                                                              determines that the individual’s
   transfer and reallocation activity to
                                                              trading activity is disruptive,
   regular U.S. mail and details of the
                                                              regardless of whether the
   individual’s trading activity may also
                                                              individual’s trading activity falls
   be sent to the fund whose shares
                                                              within the definition of Excessive
   were involved in the Excessive
                                                              Trading set forth above. Also, ING’s
   Trading activity.
                                                              failure to send or an individual’s
                                                              failure to receive any warning letter
                                                              or other notice contemplated under
                                                              this Policy will not prevent ING from
                                                              suspending that individual’s
                                                              Electronic Trading Privileges or
                                                              taking any other action provided
                                                              for in this Policy.




    http://ing.us
    Insurance products, annuities and funding agreements issued by ING Life Insurance and Annuity Company ("ILIAC"), One Orange Way, Windsor, CT 06095, which is solely
    responsible for meeting its obligations. Plan administrative services provided by ILIAC or ING Institutional Plan Services, LLC. Securities distributed by or offered
    through ING Financial Advisers, LLC (member SIPC) or other broker-dealers with which it has a selling agreement. Annuities may also be issued by
    ReliaStar Life Insurance Company (Minneapolis, MN) and ReliaStar Life Insurance Company of New York (Woodbury, NY). Variable annuities issued by ReliaStar Life
    Insurance Company are distributed by ING Financial Advisers, LLC. Variable annuities issued by ReliaStar Life Insurance Company of New York are distributed by Directed
    Services LLC. Only ING Life Insurance and Annuity Company and ReliaStar Life Insurance Company of New York are admitted and issue products in the state of New York.
    All companies are members of the ING family of companies. Products and services may vary by state and may not be available in all states.




                                                                                                                                                        HTTP://ING.US


    154907 3011051.X.P-3 (10/11) C11-1011-020 (10/11)

								
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