ing retirement plan

Your future. Made easier.®

For Plan Sponsor Use Only

A Comprehensive RetirementPlan Solution Developed for

TABLE OF CONTENTS

1. Why Choose ING?2. Flexible Investment Platform3. Comprehensive Fiduciary Solutions4. Customized Employee Communications & Tools5. Dedicated Sponsor Support & Services6. Leading with Technology7. Program Highlights8. Investment Performance9. Appendix

3016103.C.S 2 (7/10)

1.WhyChoose

ING?

Global resources, industry leadership and acommitment to making it easier for ourcustomers to achieve their retirement objectives.

Why Choose ING?

3016103.C.S 5 (7/10)

WHY CHOOSE ING?

*Pensions & Investments Ranking of Top DC Recordkeepers, April 2010

When you choose ING, you are joining forces with an organizationwith worldwide resources, undisputed leadership in the definedcontribution market and a commitment to making it easier for ourcustomers to achieve their retirement objectives.

As an industry leader providing comprehensive retirement plansolutions to more than 52,000 plan sponsors and 6.4 millionparticipants*, our success and experience in working with all typesof employers has focused our solution-driven approach to thefollowing key areas of retirement planning:

ING delivers choice and flexibility with accessto top money managers, no proprietaryvariable fund requirements and a full suite ofasset allocation options to respond to theunique needs and knowledge level of eachemployee.

ING provides the tools, services and support tohelp you understand your fiduciary responsibilities

and navigate today's ever-changingregulatory landscape.

Our personalized communications andbehavior-changing tools help educate,guide and motivate your participants to

take full advantage of plan benefits.

Our experienced, knowledgeableservice support team complements yourHR staff and are committed to making iteasier to manage your plan and easier foremployees to participate.

Dedicated SponsorSupport & Services

Flexible Investment Platform

Customized EmployeeCommunications & Tools

Comprehensive Fiduciary Solutions

ING

L E A D I N G W I T H T E C H N O L O G Y

L E A D I N G W I T H T E C H N O L O G Y

WHY CHOOSE ING?

You should consider the investmentobjectives, risks, charges and expensesof the investment options offeredthrough a retirement plan carefullybefore investing. The prospectuses/prospectus summaries containing thisand other information can be obtainedby contacting your local representative.Please read the information carefullybefore investing.

1 Pensions & Investments Ranking of Top DCRecordkeepers, April 2010

2 Datamonitor, Global Top 10 Insurance Companies -Industry, Financial and SWOT Analysis, 8/3/2009

Flexible Investment Platform

• Flexible investment options withno proprietary variable fundrequirements

• Access to well-known moneymanagers

• Target-date and risk-based assetallocation funds

• Optional Self-DirectedBrokerage option

• Fixed Account/Stable Valueoptions

ComprehensiveFiduciary Solutions

• ING Fiduciary Toolkit:– Fiduciary Investment Guide– Fiduciary Checklist– ING Fund Evaluation ScorecardSM

– Sample Investment PolicyStatement

Dedicated

Sponsor Support

& Services

Dedicated

Sponsor Support

& Services

Flexible

Investment

Platform

Flexible

Investment

Platform

Customized Employee

Communications & Tools

Customized Employee


Comprehensive

Fiduciary

Solutions

Comprehensive

Fiduciary

Solutions

ING ING

L E A D I N G W I T H T E C H N O L O G Y L E A D I N G W I T H T E C H N O L O G Y

L E A D I N G W I T H T E C H N O L O G Y L E A D I N G W I T H T E C H N O L O G Y

Morningstar® RetirementManagerSM - an investmentadvisory service fromMorningstar Associatesconsisting of Investment Advice(Managed by You) and ManagedAccounts (Managed byMorningstar) to help participantsanswer those sometimesdaunting questions about howmuch to save and whichinvestments to choose

•

Portfolio Blueprint® - a fiduciarysupport program where youbenefit from MorningstarAssociates' acknowledgement offiduciary responsibility forinvestment advisory servicesunder ERISA 3(21)(A)(ii) whileoffering your participants anindependent, unbiased,professionally-developed fundmenu and ongoing fundmonitoring for no additional fee

•

Leading With Technology

• ING’s EASE recordkeepingplatform and its superiortechnology and tools makeit easier for you to manageyour plan

• Plan Sponsor Web site provides24/7 access to plan-level,participant-level and investmentinformation

• Robust On-Demand Reportingtool allows you to quickly createboth standard and customreports with plan and participant-level detail to help improve planmetrics and identify educationopportunities to increase planawareness and drive participation

• Powerful Participant Web siteoffers one stop for transactions,information and education

• Behavior-changing participanttools seek to motivate increasedsaving, including– INGYourNumber.com– INGCompareme.com– My Retirement Outlook


• Client Relations Managerdevelops, monitors and measuresyour plan’s customizedcommunications strategy

• Education/Enrollment Specialistslead onsite enrollment andeducation meetings foremployees

• Transition Services Team assistsseparating employees

• Automatic plan featuresincluding enrollment, deferralincrease and rebalancing make iteasier for participants to save

• Customized and targetedemployee communications

• Print- and Web-based employeeeducation

• Bilingual capabilities

Dedicated Sponsor Support& Services

• Transition Manager assists withthe plan transition

• Client Relations Managercoordinates education andenrollment efforts and performsperiodic plan reviews

• Plan Manager supportsday-to-day plan operations

• Comprehensive Plan Reviewprovides up-to-date planinformation and participantactivity annually as well as helpssatisfy fiduciary responsibilities

• ING Benchmark Wizard, a data-mining tool, helps you analyzeplan data and compare yourretirement plan against similarplans in your industry

• A broad range of recordkeepingand plan services, includingautomated online payrolladministration and testing

Dedicated

Sponsor Support

& Services

Dedicated

Sponsor Support

& Services

Dedicated

Sponsor Support

& Services

Flexible

Investment

Platform

Flexible

Investment

Platform

Flexible

Investment

Platform

Customized Employee


Customized Employee


Customized Employee


Comprehensive

Fiduciary

Solutions

Comprehensive

Fiduciary

Solutions

Comprehensive

Fiduciary

Solutions

INGING ING

L E A D I N G W I T H T E C H N O L O G YL E A D I N G W I T H T E C H N O L O G Y L E A D I N G W I T H T E C H N O L O G Y

L E A D I N G W I T H T E C H N O L O G YL E A D I N G W I T H T E C H N O L O G Y L E A D I N G W I T H T E C H N O L O G Y

Morningstar® RetirementManagerSM investment advisoryservices available fromMorningstar Associates

•

ING has the scale and resources toprovide innovative solutions toretirement plans of all sizes andcomplexities. We have been in theretirement plan market since 1967,providing investment andrecordkeeping services for 401,403(b) and 457 plans.

This extensive experience enables ourcustomers to benefit from technologyand services solutions often developedand reserved for the large retirementplan market. Our ability to serviceplans across all asset levels makes iteasy for plans to grow and evolve withING as their provider. As plan assetsincrease, ING can review and adjustplan features accordingly. This uniquecapability helps the retirement plansING administers remain competitivethroughout the life of the plan.

A Close Commitment

Not only is ING is a provider with scale,reach and resources, we stayconnected to our customers bymaintaining a strong local presencethroughout the U.S. Our 40+retirement services offices enable ourING professionals to personally deliverour retirement knowledge and know-how to our customers.

ING’s Community Responsibility

Your employees can be confidentthat you’ve chosen a progressiveand community-minded companyto help them reach their retirementobjectives. At ING, we serve ourcustomers and communities intwo primary ways:

1) As a global financial servicesleader active in more than40 countries, we seek to offerthe best array of responsible,intelligent financial services.

2) As a caring corporate citizen,we aspire to share our financialknowledge and skills with thosewho need it most. It’s about helpingto make life easier and making areal difference toward positivelyimpacting the personal lives ofpeople in the community.

ING. Your future. Made easier.®

That is what we stand by. Our mission isto take away the complexity associatedwith administering and participating ina retirement plan.

WHY CHOOSE ING?

As a caring corporate citizen,we aspire to share our financialknowledge and skills with thosewho need it most.

• ING Chances for Children is ourglobal community developmentprogram that engages ouremployees and customers inefforts to improve access to qualityeducation for children around theworld. Since the launch of theprogram in 2005, thousands ofING employees have supportedING Chances for Children asdonors and volunteers.

• In partnership with GirlsIncorporated, we created a pilotprogram called the ING-Girls Inc.Investment Challenge — aninnovative program that givesparticipating girls practical, hands-oninvesting experience while allowingthem to keep their gains in theform of college scholarships.

• To address the issue of childhoodobesity, ING developed the INGRun for Something Better programto introduce kids to the benefits ofrunning, a habit of physical fitnessand healthy lifestyle choices.Founded in 2003, thousands ofstudents have run more than1.2 million miles through thisfree, school-based program.

• ING believes that everyone has animportant role to play in beingenvironmentally responsible.Therefore, wherever we work, westrive to minimize our environmentalimpact and use environmentallysustainable materials and methodsthroughout our operations anddaily activities.

3016103.C.S 6 (7/10)

2.Flexible

Investm

entPlatfo

rm

ING’s flexibility offers you more choice in designingan investment menu that responds to the uniqueneeds and knowledge level of each employee.

Flexible InvestmentPlatform

3016103.C.S 7 (7/10)

ING’s flexible investment platform lets you choose from many well-known fundfamilies to create your plan’s investment menu.

Fund Offerings Withinthe ING Platform

More Choice, No ProprietaryVariable Fund Requirements

ING has strong, strategic relationshipswith many leading investmentproviders located throughout theworld. These relationships allow us tooffer you the very best in investmentalternatives with a menu that is bothextensive and diverse. Unlike manyproviders, ING has no proprietaryvariable fund requirements, giving youmore choice and flexibility in designingan investment menu best suited foryour employees.

1 Sub-adviser of funds included in ING Partners, Inc. Directed Services LLC. is the investment adviser for these funds.2 Fidelity and Fidelity Investments (Pyramid) Design are registered trademarks of FMR Corp.3 Franklin and Templeton are registered trademarks of Franklin Resources, Inc. or its subsidiaries.4 MFS® and/MFS Investment Management® are registered trademarks of Massachusetts Financial Services Company.5 “T. Rowe Price,” “Invest With Confidence,” and the “Big Horn Sheep” logo are registered trademarks of T. Rowe Price Group, Inc.

ING’s menu of sub-advised investment options are offered through two ING-affiliated investment companies, ING Partners, Inc.(IPI) and ING Investors Trust, Inc. (IIT). In the case of the investment options referenced within this material, it is important to notethat the third-party manager serves as the sub-advisor. Directed Services, Inc. (DSI) also an ING-affiliated company, serves as theadvisor for IPI and IIT.

1

2

1

1

1

1,5

Construct a competitive fund menu of choicewith outside retail funds managed by topindependent fund managers.

A simple solution of institutionally pricedinvestments sub-advised by some of today’s topmoney managers.

Take advantage of ING InvestmentManagement’s institutional money managementexpertise with global, fixed income and assetallocation investment options.

OUTSIDEFUNDS

SUB-ADVISEDFUNDS

PROPRIETARYFUNDS

3

1,4

FLEXIBLE INVESTMENT PLATFORM

5


Our platform allows you to design aninvestment menu that responds to theneeds and knowledge level of eachemployee. Investment optionsavailable through ING represent assetclass categories spanning therisk/reward spectrum, from high risk,Global Funds to more conservativeStable Value (and Fixed Account)options. For those who want moreinvestment options, access tothousands of mutual funds is availablevia a Self-Directed Brokerage Accountoption. ING's Solution suite of target-date and risk-based portfolios offersparticipants a simpler decision makingapproach to saving through the plan.

ING’s Target-Date and Risk-BasedPackaged Asset AllocationSolutions

Making it easier—it’s what ING strivesto do for all our customers in allaspects of our business. And this isespecially true when it comes to planinvestments—one of the mostimportant aspects of your retirementplan. ING’s Solution suite of target-date and risk-based portfolios isdesigned to help make assetallocation decisions easier whiletaking into account the time horizonand risk tolerance of each participant.

Self-Directed Brokerage Account

For more sophisticated investors whodesire flexibility beyond the plan’score investment options and want tomanage his or her own investments,we offer a Self-Directed BrokerageAccount. It provides access to otherinvestments previously unavailableunder retirement plans, including:• Over 10,000 mutual funds fromsome of the most well-knownand respected mutual fundcompanies, including more than950 mutual funds available withouttransaction fees

• Fixed income securities• Individual stocks listed on themajor U.S. exchanges

ING Fixed Account andStable Value Options

To help mitigate the volatility ofriskier investment options, ING offersseveral Fixed Account and StableValue options.

The Fixed Account is a fixed interestinvestment option available withinING’s retirement programs thatguarantees a minimum rate ofinterest and may credit interest thatexceeds the minimum guaranteedrate. Once credited, the interestbecomes part of the principal and theinvestment grows through compoundinterest. All assets invested in thisaccount, which are invested in INGLife Insurance and Annuity Company’sGeneral Account, receive the samecredited rate, which is known as themethod of interest rate crediting.ING’s experience in managing fixedassets dates back to 1966.

Depending on plan characteristics,one or more stable value alternativesmay also be available. Such stablevalue options may include a stablevalue investment option availablethrough a collective trust or a stablevalue contract offered through aninsurance company separateaccount contract.

Some restrictions may apply totransfers. Principal and interestguaranteed by ING Life Insurance andAnnuity Company as applicable. Amarket value adjustment may applyto withdrawals. All guarantees arebased on the financial strength andclaims paying ability of ING LifeInsurance and Annuity Company,who is solely responsible for allobligations under its policies.

Employees wantto feel confidentand in control oftheir investmentchoices. ING hasoptions for everytype of investor.

Morningstar® RetirementManagerSM

This service offers two uniquesolutions that recognizeparticipants don’t have to beinvesting experts to save forretirement. Investment Advice(Managed by You) and ManagedAccounts (Managed byMorningstar) consider that someparticipants may enjoy activelymanaging their accounts, whileothers may prefer to have aprofessional investment managerdo it for them.

Morningstar Retirement Managergives participant the opportunityto receive a personalizedretirement strategy. Participantscan then choose the solution thatbest suits their needs –implementing advice themselvesor delegating accountmanagement responsibility toMorningstar Associates.

ING TARGET-DATE SOLUTION PORTFOLIOSSM Asset AllocationDecisions Made Easier

ING’s Target-Date SolutionPortfolios are designed tohelp employers:

• Give employees an easierway to invest for retirement

• Increase plan participationthrough streamlineddecision-making processes

• Potentially reduceemployee investment riskthrough a fund-of-fundsapproach

• Satisfy Qualified DefaultInvestment Alternativerequirement (QDIA)

How the Portfolios WorkMulti-manager Approach

The ING Target-Date SolutionPortfoliosSM represent a “Fund ofFunds” strategy. Rather than investingin individual securities (such astraditional balanced or asset allocationfunds), these portfolios invest in anunderlying portfolio of investmentoptions available in ING’s productlineup.

This Fund of Funds strategy alsoleverages ING’s sub-advised fundplatform, meaning many underlyingfunds are managed by well-knownoutside fund managers that include:• Artio Global Investors• Baron Funds• BlackRock• Columbia Wanger AssetManagement

• Davis Funds• Franklin Templeton Investments• Goldman Sachs Asset Management• J.P. Morgan• Marisico Funds• PIMCO• Pioneer Investments• Thornburg Investment Management• T. Rowe Price

The ING Target-Date SolutionPortfolios utilize an actively managedset of funds, and the ING Target-DateIndex Solution Portfolios utilize apassively managed set of funds.

ING’s investment professionals havedetermined the allocation targets foreach portfolio based on a host of bothqualitative and quantitative analysis,including current and future marketvolatility and conditions, as well asforward looking inputs. The Portfoliosare rebalanced at least quarterly and,over time, each Portfolio migrates to amore conservative investment mix –so participants won’t have torebalance for themselves asinvestment goals near.

Diversification on Two Levels:

� Within each ING SolutionPortfolio, and

� Within the underlying funds

�

�

IMPORTANT INFORMATION: There is no guarantee that any investment option will achieve its stated objective. Principal value fluctuatesand there is no guarantee of value at any time, including the target date. The "target date" is the approximate date when you plan to startwithdrawing your money.When your target date is reached, you may have more or less than the original amount invested. For each target datePortfolio, until the day prior to its Target Date, the Portfolio will seek to provide total returns consistent with an asset allocation targeted for aninvestor who is retiring in approximately each Portfolio's designation Target Year. The Target Year is specified in the Portfolio's name. Forexample, the ING Solutions 2045 Portfolio bears an asset allocation that the investment adviser believes balances the risk and return objectivesof the "average" investor who will be retiring in the year 2045.With the exception of ING Solution Growth and Income Portfolio, ING SolutionGrowth Portfolio, ING Solution Income Portfolio and ING Index Solution Income Portfolio, each Portfolio is structured and managed around aspecific target retirement or financial goal date (”Target Date”) as follows: 2055, 2045, 2035, 2025 and 2015. The ING Solution Growth andIncome Portfolio, ING Solution Growth Portfolio, ING Solution Income Portfolio and ING Index Solution Income Portfolio are for those who areretired, nearing retirement or in need of drawing down income from their Portfolio soon. Prior to choosing a Target Date Portfolio, investors arestrongly encouraged to review and understand the Portfolio's objectives and its composition of stocks and bonds, and how the asset allocationwill change over time as the target date nears. No two investors are alike and one should not assume that just because they intend to retire inthe year corresponding to the Target Date that that specific Portfolio is appropriate and suitable to their risk tolerance. It is recommended thatan investor consider carefully the possibility of capital loss in each of the target date Portfolios, the likelihood and magnitude of which will bedependent upon the Portfolio's asset allocation.On the Target Date, the Portfolio's investment objective will be to seek to provide a combination of total return and stability of principalconsistent with a low to moderate risk asset allocation which is targeted to the "average" retiree.Stocks are more volatile than bonds, and portfolios with a higher concentration of stocks are more likely to experience greater fluctuations invalue than portfolios with a higher concentration in bonds. Foreign stocks and small and midcap stocks may be more volatile than large capstocks. Investing in bonds also entails credit risk and interest rate risk. Generally investors with longer timeframes can consider assuming morerisk in their investment portfolio. The ING Solution PortfoliosSM are actively managed and the asset allocation adjusted over time. The portfoliosmay merge with or change to other portfolios over time. Refer to the prospectus for more information about the specific risks of investing in thevarious assets classes included in the ING Solution Portfolios.


CHOICE:You decide what is best

Every plan is different andhas unique needs based onthe employee population.Target-date investmentportfolios, whether theycontain actively or passivelymanaged funds, help:• Meet your fiduciaryrequirements

• Increase plan participation• Encourage long-terminvesting

Regardless of whichinvestment strategy youchoose, it should remain along-term, disciplinedapproach. Your financialprofessional is always availableto assist you with this decisionand can help you find themost appropriate solution foryour retirement plan's uniquecircumstances.

Goal years: 2051+Designed for people who plan to begin living their retirementgoals during or after the year 2051.These are the most aggressive Portfolios.

Goal years: 2041 to 2050Designed for people who plan to begin living their retirementgoals in the years 2041 – 2050.These are aggressive Portfolios.

Goal years: 2031 to 2040Designed for people who plan to begin living their retirementgoals in the years 2031 – 2040.These are moderately aggressive Portfolios.

Goal years: 2021 to 2030Designed for people who plan to begin living their retirementgoals in the years 2021 – 2030.These are moderate Portfolios.

Goal years: 2011 to 2020Designed for people who plan to begin living theirretirement goals in the years 2011 – 2020.These are moderately conservative Portfolios.

Goal year: 2010Designed for people who plan to begin living theirretirement goals in the year 2010.These are conservative Portfolios.

GL

SM LG

LV

BD

GLSM

LG

LV

BD

GL

SM

LGLV

BD

GL

SM

LG

LV

BD

GL

SM

LG

LV

BD

ASSET CLASSES KEY

� BONDS (BD)

� LARGE CAP VALUE (LV)

� LARGE CAP GROWTH (LG)

� SMALL/MID/SPECIALTY (SM)

� GLOBAL/INTERNATIONAL (GL)

The pie charts displayed reflect the long-term, strategic asset allocationcomposition (“Target Allocations”) and are reviewed periodically,however, changes to these target allocations may occur on a quarterlybasis or as warranted by market conditions. Please refer to theprospectus for more information.

GL

SM LG

LV

BD

Target-Date Investment Portfolios

Today:Initially, the portfoliowill include a mix of

more aggressive domesticand global/internationalstock funds, along witha small allocation to

income funds.

20 years from now:Some money is gradually

shifted out of more aggressivestock funds and into moreincome-oriented funds.

40 years from now:Even less is kept in stockfunds and more allocatedto income and stability

of principal.

Hypothetical Example: ING Solution 2045 Portfolio (long-term portfolio)

Today In 10 years In 20 years In 30 years In 40 years

GL

SM

LG

LV

BD GL

SM

LGLV

BDGL

SM

LG

LV

BD

GLSM

LG

LV

BD

GL

SM LG

LV

BD

Advantages of ING Risk-BasedSolution Portfolios

ING Investment Management is aleader when it comes to managingasset allocation portfolios. Our multi-manager investment approach,disciplined portfolio constructionprocess and experienced investmentteam combine to make the INGRisk-Based Solution Portfolios thechoice for asset allocation solutionswithin a retirement plan.

• Multi-Manager InvestmentApproach – Access to a wide choiceof world-class asset managers whobring diverse global insights andresources to each Portfolio andenhance the Portfoliosdiversification potential

• Disciplined Portfolios Construction –Enhances accumulation potentialover time with access to more than60 funds managed by 26 leadingfund managers

• Experienced Investment Team –More than 26 years managing assetallocation portfolios

• Satisfies Qualified DefaultInvestment Alternative (QDIA)requirement

Asset AllocationDecisions Made Easier

Risk-Based Funds

ING Risk-Based SolutionPortfolios offer comprehensiverisk-based asset allocationsolutions for retirement plans.Participants can choosethe appropriate portfoliothat aligns with theirindividual risk profile andING Investment Managementwill manage the day-to-dayportfolio asset allocation andinvestment decisions.

The ING Risk-Based SolutionPortfolios are a complete risk-basedmulti-manager asset allocation fundsolution for your participants.


ING Solution Conservative PortfolioInvestment Objective:The Portfolio seeks to provide growth of capital and current income.Investment Strategy:The Portfolio invests in a combination of underlying funds accordingto a fixed formula that over time should reflect an allocation ofapproximately 30% in equity securities and 70% in fixed-incomesecurities and cash.

ING Solution Moderate PortfolioInvestment Objective:The Portfolio seeks to provide growth of capital and current income.Investment Strategy:The Portfolio invests in a combination of underlying fundsaccording to a fixed formula that over time should reflect anallocation of approximately 50% in equity securities and 50% infixed income securities.

ING Solution Moderate Growth PortfolioInvestment Objective:The Portfolio seeks to provide growth of capital and a low tomoderate level of current income.Investment Strategy:The Portfolio invests in a combination of underlying fundsaccording to a fixed formula that over time should reflect anallocation of approximately 70% in equity securities and 30% infixed income securities.

ING Solution Aggressive Growth PortfolioInvestment Objective:The Portfolio seeks to provide growth of capital.Investment Strategy:The Portfolio invests in a combination of underlying fundsaccording to a fixed formula that over time should reflect anallocation of approximately 90% in equity securities and10% in fixed income securities.

GL

SMLG

BL

LV

BD

SP

ASSET CLASS ALLOCATION

GLOBAL/INTERNATIONAL EQUITIES (GL) 6%

SMALL/MID CAP (SM) 3%

LARGE CAP GROWTH (LG) 3%

LARGE CAP CORE (BL) 14%

LARGE CAP VALUE (LV) 5%

BONDS (BD) 49%

STABILITY OF PRINCIPAL (SP) 20%

24% U.S. Equity6% Global/Intl Equity70% Bonds

GL

SM

LG

BL

LV

BD

SP




SMALL/MID CAP (SM) 7%




BONDS (BD) 35%


GL

SM

LG

BL

LV

BD

SP



GLOBAL/INTERNATIONAL EQUITIES (GL)18.5%

SMALL/MID CAP (SM) 9.5%



LARGE CAP VALUE (LV) 14.5%

BONDS (BD) 20.5%


GL

SM LG

BL

LV

BD



SMALL/MID/ CAP (SM) 16%




BONDS (BD) 9%


The Solution Risk-Based Portfolios will invest based on target allocations. Rebalancing will take place at least monthly. These allocations are targets and each Portfolio’s allocationscould change substantially as the underlying funds' asset values change due to market movements and portfolio management decisions. Each Portfolio's target asset allocationstrategy will be reevaluated quarterly and will be rebalanced to reflect changes.

Portfolio Allocations for Each Stage of Retirement Planning

ING offers four Risk-Based Solution Portfolios to meet participant needs as theyprepare for retirement. Investors can select the appropriate ING Risk-BasedSolution Portfolio based on their individual risk profile. It is important forinvestors to regularly assess their risk profile to ensure that they are invested in aportfolio that appropriately meets their needs over time as they approachretirement.

3016103.C.S 8 (7/10)

Morninstar® Retirement ManagerSM

Managed by Morningstar

ING has teamed up with MorningstarAssociates, LLC, a leading providerof investment advisory services, tomake available Managed byMorningstar managed accountservice. This service works well forparticipants who lack the time,know-how, or desire to activelymanage their retirement account.

When participants choose theManaged by Morningstar solution,they receive professional oversightfrom Morningstar. Morningstar willdefine a retirement savings goal andconstruct a portfolio based on theparticipant’s personal situation. Duringthis process, Morningstar selects theinvestments for that participant fromthe available investment options. Inaddition, on a quarterly basis,Morningstar reviews participants’portfolios and rebalances eachaccount as necessary. A quarterlyProgress Report is also available thatoutlines the participant’s progresstoward his or her retirement goal.

With this fee-based service, theparticipant benefits from theconfidence in knowing that aprofessional investment manager isimplementing a customized strategyand overseeing his or her retirementaccount assets. For the Managed byMorningstar service, Morningstar actsas the investment manager withdiscretionary authority and acceptsfiduciary responsibility over only theplan accounts of those participantswho have enrolled in the service.

IMPORTANT: The projections or other information generated by Morningstar® Retirement ManagerSM regarding thelikelihood of various retirement income and/or investment outcomes are hypothetical in nature, do not reflect actual results(including investment results) and are not guarantees of future results. Results may vary with each use and over time.Annual Retirement Income Outlook considers such things as your asset mix and Morningstar Associates’ own forecasts for return, risks andcorrelation for various asset classes. The Expected Retirement Income noted within the tool is the amount the simulation has determined ashaving a 90% probability of being achieved. Annual Retirement Income Goal is calculated by taking 70% of your projected salary atretirement, expressed in today's dollars. Your projected salary at retirement is determined by a proprietary salary growth curve and yourprojected social security benefits. Morningstar Associates' salary growth curve assumes your salary will grow at rates that vary with your age.Projected social security benefit is based off of an algorithm supplied by the Social Security Administration. Proposed Asset Mix is derived fromvarious factors such as your years to retirement, your projected salary growth and results from an asset liability analysis. The asset-liabilityanalysis is an economic concept that is helpful in understanding your ability to withstand financial losses by incorporating a projected futurestream of income into your current financial situation. Morningstar Retirement Manager is provided by Morningstar Associates, LLC(“Morningstar Associates”), a registered investment advisor and a wholly owned subsidiary of Morningstar, Inc., and is intended for citizensand legal residents of the United States and its territories. Morningstar Associates' advisory service relates solely to the investment optionsoffered under the plan. Retirement plan funding products are offered through ING Financial Advisers, LLC (member SIPC) or other brokerdealers with which it has selling agreements. ING provides Morningstar Associates with the plan's investment options and information aboutparticipants but the decisions regarding the advice provided are made by Morningstar Associates. ING and its companies are not affiliated withMorningstar Associates or its affiliates, and receive no fee or other direct financial benefits from Morningstar Associates in connection with theuse of its services. The Morningstar name and trademarks are used under license from Morningstar Associates.

3016103.C.S 9 (7/10)

Did You Know?According to analysis*

conducted by Morningstar

Associates, LLC., results

indicated that participants

who enrolled in the

Managed by Morningstar

service:

• Were saving more, better

diversified and improving

their retirement income

prospects,

• Recognized an average

increase in deferral rate

of 2%, and

• Had a 9% change in

retirement income

outlook, which is an

average increase in

estimated annual

retirement income of

more than $3,300 a year.

*Source: Morningstar Associates' proprietary data as of 3/31/2010. The data includes statistics from an analysis of 2832 retirement plan participants. This group includesparticipants who enrolled in the Managed by Morningstar service through the website, are currently enrolled in the service and have been enrolled for atleast six months.However, this group excludes users that are enrolled in an automatic escalation program and participants with company stock and outside assets. The percent improvement inretirement income was calculated as the percentage change between the average initial retirement income outlook and the average retirement income outlook based on ourrecommendations for each age group and in total. The actual improvement in average deferral rate was calculated as the change in the average deferral rate before enrolling inManaged by Morningstar as compared to the average deferral rate change after enrolling in the Managed by Morningstar program. Average and median salary figures representthose statistics for each age group for the data sampled.

3.Compreh

ensive

Fiduciary

Solutio

ns

ING’s fiduciary support helps you understandyour fiduciary responsibilities and navigatetoday’s ever-changing regulatory landscape.

ComprehensiveFiduciary Solutions

3016103.C.S 10 (7/10)

COMPREHENSIVE FIDUCIARY SOLUTIONS

Your responsibilities as a fiduciary

ERISA provides standards of conduct for fiduciaries. Specifically,

section 404(a) created the following rules to govern the conduct

of fiduciaries:

1. Duty of Loyalty – A fiduciary must discharge his duties solely inthe interest of plan participants and beneficiaries.

2. Exclusive Purpose Rule – A fiduciary shall discharge his duties forthe exclusive purpose of:

• Providing benefits to participants and their beneficiaries;

• Defraying reasonable expenses of administering the plan.

3. Prudent Man Rule – Requires that a fiduciary perform his/her

duties in a manner of a prudent person with the care, skill,

prudence and diligence of a person acting in a like capacity and

knowledgeable about such duties.

4. Diversify Plan Assets – A fiduciary must ensure that assets aresufficiently diversified so as to minimize the risk of large losses,

unless it is clearly prudent not to do so.

5. Act in accordance with plan documents – ERISA requiresfiduciaries to operate the plan in accordance with the terms of

the written plan document and other instruments that

govern the plan.

ING does not assume any fiduciary responsibility for your plan. You should consult with yourattorney prior to making any decision.

Did You Know?• Between 2001 and

September 2009, the

Department of Labor

(DOL) closed 12,805 civil

investigations of

inappropriate use of

funds in 401(k) plans*

• 83% resulted in monetary

or corrective action*

• In fiscal year 2009, a total

of 1,106 civil and criminal

401(k) investigations were

closed with settlements

among those with

corrective action totaling

nearly $18 million*

* U.S. Department of Labor, EmployeeBenefits Security Administration,October 2009

ING works with you every step ofthe way to help ensure you meetyour requirements:• In understanding and developingcriteria to be considered in theselection and periodic evaluation

of the investment options offeredto plan participants;

• In creating an InvestmentPolicy Statement and investmentguidelines for your plan; and

• In developing investment-relatedcommunications for plan participants.


FiduciaryResponsibilities

Establishment ofwritten policies andguidelines that formthe basis of thefiduciary’s decisionsand actions

Selection andongoing evaluationof investmentoptions

Diversification ofinvestment options

ERISA Section404(c) compliance

FiduciaryConsiderations

Does a written investmentpolicy statement guide yourinvestment decisions?

Is your statement periodicallyreviewed to ensure its relevanceto the plan’s objectives andparticipant needs?

Do you possess the necessaryexpertise or should you seekadvice or assistance?

Are you able to exercise theappropriate care and prudencein assessing the investmentsfor initial selection andevaluating those investmentdecisions over time?

Are there enough investmentoptions with different risk andreturn characteristics?

Are there appropriateopportunities for participantsto help minimize their risk byspreading assets across thethree main categories ofinvestments (Growth/Equities,Income/Bonds and Safety ofPrincipal/Cash)?

Are there enough options thathave the potential to providereturns over the long term thatcould outpace inflation?

Is it intended that the plan willcomply with ERISA Section404(c)?

The 404(c) regulations containsubstantive requirementsconcerning the investmentoptions and information aboutthose options that must begiven to participants.

ING FiduciarySolutions

Fiduciary Investment Guide

Periodic plan reviewwith benchmarking

Sample Investment PolicyStatement

Periodic plan reviewwith benchmarking

Investment selection guide

ING Fund EvaluationScorecardSM

Broad investment optionsacross risk/reward spectrum

Fixed Account/Stable Value Option

Self-DirectedBrokerage Option

ING Target-Date SolutionPortfolios

ING Risk-Based SolutionPortfolios

Make prospectuses available

Fund performance summaries

Asset allocation software tools

Quarterly reports/newsletters

Participant educationalmaterials

Informative Web sites

Investment descriptions

Typically, a fiduciary responsible for selecting investments to be offeredunder a Defined Contribution plan has many issues to consider:

You should consider the investmentobjectives, risks, charges and expensesof the investment options offeredthrough a retirement plan carefullybefore investing. The prospectuses/prospectus summaries containing thisand other information can be obtainedby contacting your local representative.Please read the information carefullybefore investing.

Variable investment options offered in aretirement plan are considered long-terminvestments designed for retirementpurposes. If withdrawals are taken prior toage 591⁄2, an IRS 10% premature distributionpenalty tax may apply. Money will be taxedas ordinary income in the year it isdistributed and early withdrawal penaltiesmay apply. Account values fluctuate withmarket conditions, and when redeemed theprincipal may be worth more or less than itsoriginal amount invested.

Portfolio Blueprint®

Morningstar® RetirementManagerSM

ING Fiduciary ChecklistHelping plan sponsors manage their fiduciary responsibilities

� Plan document (including adoptionagreement and prototype document),summary plan description (SPD), andall amendments

� Plan’s determination letter(if requested)

� Copies of forms 5500 and summaryannual report (SAR), including allschedules

� Accountant’s opinion (if required)

� ADP/ACP test (unless the plan haselected safe harbor provisions)

� Fidelity (ERISA) bond� Investment policy statement (IPS)� Valuation report showing assets by fundand participant accounts by money type

� Investment report from provider andannual plan review report

� List of service providers, includingbroker, RIA, or consultant; mutual fund,or other investment provider; and thirdparty administrator (TPA)

� List of authorized plan sponsorrepresentatives for plan/ investmentcommittee; obtaining plan benefits,if applicable

� Plan/investment committee minutes

www.ing-usa.com www.ingretirementplans.comThis material is provided as a helpful resource. ING does not offer legal or tax advice. Seek the advice of a tax attorney or tax advisor prior to making a tax-relatedinvestment decision.

Insurance products, annuities and funding agreements issued by ING Life Insurance and Annuity Company ("ILIAC") One Orange Way, Windsor, CT 06095, which is solelyresponsible for meeting its obligations. Plan administrative services provided by ILIAC or ING Institutional Plan Services, LLC. All companies are members of the ING familyof companies. Securities distributed by or offered through ING Financial Advisers, LLC (member SIPC) or other broker-dealers with which it has a selling agreement.Products and services may not be available in all states. © 2009 ING North America Insurance Corporation. C08-0620-010 (7/08)

Your future. Made easier.®3013207.X.S (9/09)

PLAN NAME: __________________________________________________________________________________________

SERVICE PROVIDER: _____________________________________________________________________________________

ADMINISTRATIVE PROVIDER: ______________________________________________________________________________

DATE LAST REVIEWED: ___________________________________________________________________________________

Documents: Type or write an X next to each of the documents you have on file for your organization’s retirement plan.

1. Plan Design and Check-Up:� Eligibility� Entry dates� Matching� Vesting� Loan and or hardships� Mandatory distributions and automaticrollovers

� Compensation

2. Investment Review:� Investment policy statement� Asset classes covered

� Performance, investment risk taken,operating costs, and managementturnover

� Funds watch listed or replaced� Annually � Semiannually � Quarterly

3. Review of Participant Investing:� Use of Lifecycle or Lifestyle funds� Review and establish or confirm defaultinvestment for the plan

� Investment education meetings� Advice� 404(c) compliance

4. Operations:� Timely deposit of plan contributions andloan repayments

� Enrollment and education meetings:Offered? Attended?

� Fees and costs paid by the plan� Meetings with financial advisor,provider: TPA

� Notice Requirements

Plan Operations: Type or write an X next to each item that you’ve reviewed.

Action Items

The Employee Retirement IncomeSecurity Act (ERISA) of 1974

ERISA was intended to protect theretirement savings of millions ofAmerican workers. However, withthat comes a duty to meet numerousrules and regulations that are oftenhard to understand and can burdenthe companies that provideretirement plans.

Be Confident in YourFiduciary Role

ING believes fiduciaries should havethe help they need to be confident intheir fiduciary role. With our FiduciaryToolkit, gaining that confidence justgot easier.

ING Fiduciary Toolkit

ING can help you understand andmanage your fiduciary responsibilities.The toolkit is comprised of many toolsto assist you in selecting andmonitoring your investment options.

1. The Fiduciary Investment Guideprovides you a framework forcarrying out the fiduciaryresponsibilities associated withselecting and monitoringinvestments in their plan. Theguide helps by simplifying thesteps fiduciaries need toconsider when sponsoring aretirement plan, including:• Establishment of written policies• Selection and ongoing evaluationof investment options

• Diversification of investmentoptions

2. A sample Investment PolicyStatement (IPS) provides aframework for you to work withyour legal counsel to craft an IPSthat is tailored to their plan. TheIPS defines how the investmentoptions and investment managersare selected, monitored, andevaluated. It also describes howthe investment objectives arerelated to investment decisions.

Plan and Trust Name: _______________ (“Plan”). This Investment Policy Statement is adopted for the Plan by_______________ (Plan Fiduciary). The Plan provides for individual accounts and permits participants (orbeneficiaries) to exercise investment control over the assets in their accounts.

The Plan’s overall investment objective is to provide Plan participants (or beneficiaries) with a sufficient variety ofinvestment options to enable participants to achieve their individual investment goals for retirement. To accomplishthis, the Plan may enter into group annuity contracts or agreements with financial services providers that offer a widevariety of investment options and benefit distribution facilities. The investment options should represent multipleasset classes covering equity (stock), fixed income (bond), money market or stable value, and balancedoptions/Lifestyle/Lifecycle. These investments will have the following general characteristics:

• Different risk/return characteristics;• Different investment objectives and styles;• Annualized returns over three-, five- and ten-year periods that have met or exceeded the competitive averagesor established industry benchmarks; and

• Reasonable operating expenses and/or minimum guaranteed rates of return, as applicable, that are disclosedto participants.

Standards for Investment Option SelectionThe selection of particular investment options will be based on the standards listed below. It is the intent to haveinvestment options that represent a diversified mix of asset classes and styles, comprising approximately _______choices. Included in the selections: active and passive/index-like options, equity options across capitalization ranges(small, mid and large capitalization) and style categories (growth, blend and value) as well as international equityexposure (foreign or global), fixed income and Lifecycle or Lifestyle options.

Income option selection will generally focus on credit quality (investment grade, high yield) and maturity period(short, intermediate, long term). Stable value option selection will generally focus on credited rate structures, the ade-quacy of any minimum guarantees, and the claims paying abilities of the underlying insurer(s). Index fund selectionwill focus on the reasonableness of fund expense ratios and correlation to the index benchmark.

For investment options other than index funds, stable value funds and income funds, the Plan fiduciary will establisha reasonable universe of diversified investment funds with similar investment styles for each targeted asset class andthen make selections from that universe based on the following standards:

1. Operating Expenses: the expense ratio of the funds will be evaluated for reasonableness with a preference forlower cost funds except where additional cost can be justified by other factors.

2. Risk-adjusted returns: as measured by Sharpe Ratio: historical investment performance relative to risk and acomparison of risk/return tradeoff versus peers.

3. Performance: the investment performance of the fund as reflected by total trailing annualized returns, rollingwindow performance and Alpha, a measure of value added by a manager.

Fiduciary Investment Guide

Your future. Made easier.SM

Helping to make it easier to understand fiduciary responsibilities.

For sponsor use only.

Sample Investment PolicyStatement

Your plan’s investmentobjectives should bedocumented in its InvestmentPolicy Statement. Thisimportant document alsosets a schedule to regularlyreview the continuedappropriateness of yourplan’s investment options.Each plan should have anInvestment Policy Statementon file. The sampleInvestment Policy Statementis offered as a resource todraft your own if you haven’talready done so. If youchoose to use this document,be sure to review it with yourlegal counsel to ensure that itsufficiently meets the needsof your plan.

Fiduciary Checklist lists plandocument and organizationalrequirements to assist with yourannual plan review

Fiduciary Investment Guideprovides you a framework forcarrying out your fiduciaryresponsibilities

3. Also included is the ING FiduciaryChecklist, which lists plandocument and organizationalrequirements in an easy-to-usereference tool. This tool will assistyou in your annual plan review.

4. The ING Fund EvaluationScorecard has been independentlycertified by Wilshire as a sound andprudent tool. The Fund EvaluationScorecard is a proprietary analyticaltool that offers a detailedinvestment option review to helpyou with fund selection processes:

• Analyzing fund characteristics• Comparing investments withinasset classes

• Monitoring investments on anongoing basis when usingScorecard reports consistentlyover time


As of March 31, 2010

Created with MPI Stylus with data provided by MorningstarFund Number: 001 Page 2 of 3

I NG Fund Evaluation Scorecard I NG Growth and I ncome Portfolio - Class I

PERFORMANCE

FundS&P 500I ndex

Universe

Total Total Total(5% )Total(25% ) Total(Median)Total(75% )Total(95% )

1 year 49.19 49.77 73.58 52.67 49.17 45.74 38.523 year -3.10 -4.17 0.01 -3.06 -4.23 -5.26 -8.725 year 2.80 1.92 5.27 2.86 1.79 1.07 -1.1610 year -2.14 -0.65 5.46 1.98 -0.28 -1.15 -3.28

Performance: Total Average Annual Return

-12-8-4048

121620242832364044485256606468727680

Tota

lAnn

ualiz

edRet

urn,

%

1 year 3 year 5 year 10 year

5th to 25th Percentile 25th Percentile to Median Median to 75th Percentile 75th to 95th PercentileFund S&P 500 Index

Performance: 24 Month Rolling Quarter

-40

-30

-20

-10

0

10

20

30

Tota

lAnn

ualiz

edRet

urn,

%

Mar-02 Dec-02 Dec-03 Dec-04 Dec-05 Dec-06 Dec-07 Dec-08 Mar-10

5th to 25th Percentile 25th Percentile to Median Median to 75th Percentile 75th to 95th PercentileTotal

Peer Group: Large Blend Number of Funds: 954

SCORI NGCategory Category Rank Points Weighted Score

PERFORMANCE1, 3, 5, 10 Year Average 45 3 1.824-Month Rolling Returns 70 224-Month Rolling Alpha 77 1

RI SKStandard Deviation 53 2 1.0Upside / Downside Market Capture C 3

RI SK-ADJUSTED PERFORMANCESharpe Ratio 77 1 1.0Scattergram CN 4

CONSI STENCY OF STYLEAverage Style 10.65 5 1.0

EXPENSE CRI TERI ATotal Fund Expenses: 0.60% 20 4 0.4Peer Group Median: 0.98%

OVERALL EVALUATI ON (Ten Years or Since I nception)

5.2Peer Average

MI D TERM EVALUATI ON ( Five Years or Since I nception)

7.4 Very Good

The mid term evaluation utilizes the same methodology using a five-year trailing time period. This is designed to augment the longer term evaluation of the standard ING Fund Evaluation Scorecard process. This may be helpful in conjunction with the full Scorecard report.

GENERAL FUND I NFORMATI ONBatting Average: 583 Ticker: IIVGX

Cash Holdings: 3.32% % of Assets in Top 10 Holdings: 31.47%

Turnover Ratio: 104% Total Number of Holdings: 72

R Squared: 97.80

Apr-05 - Mar-06Apr-06 - Mar-07Apr-07 - Mar-08Apr-08 - Mar-09Apr-09 - Mar-1015.66 9.09 -4.70 -36.01 49.19

18 80 36 26 50

Alpha: 24 Month Rolling Quarter

-10

-5

0

5

Alph

a,%


FundAlpha

12 Month Trailing Returns and Peer Group Rank

For more specific performance of the options available within your plan, please see the plan level performance summary at the end of this document.

As of March 31, 2010

Created with MPI Stylus with data provided by MorningstarFund Number: 001 Page 3 of 3

I NG Fund Evaluation Scorecard I NG Growth and I ncome Portfolio - Class I

RI SK

CONSI STENCY OF STYLE

Upside / Downside Market Capture

Previous 60 Months

0

20

40

60

80

100

120

140

160

180

200

Up

Mar

ket

Capt

ure

Rat

io,%

0 20 40 60 80 100 120 140 160 180 200 220 240

Down Market Capture Ratio, %

Large Blend Peer Group Fund

Standard Deviation: 24 Month Rolling Quarter

0

5

10

15

20

25

30

35

Tota

lAnn

ualiz

edSt

dDev

,%


5th to 25th Percentile 25th Percentile to Median Median to 75th Percentile 75th to 95th PercentileTotal

RI SK ADJUSTED PERFORMANCE

Risk-Adjusted Performance: Scattergram

Previous 60 Months

-8

-6

-4

-2

0

2

4

6

8

10

12

Tota

lAnn

ualiz

edRet

urn,

%

0 9 18 27 36

Total Annualized StdDev, %

Large Blend Peer Group Fund

Sharpe Ratio: 24 Month Rolling Quarter

-2

0

2

4

Shar

peRat

io


5th to 25th Percentile 25th Percentile to Median Median to 75th Percentile 75th to 95th PercentileSharpe Ratio

Consistency of Style: Dynamic Style Exposure - Trailing 10 yrs or Since I nception

0

10

20

30

40

50

60

70

80

90

100

Wei

ght,

%

Apr-00 Dec-00 Jun-01 Dec-01 Jun-02 Dec-02 Jun-03 Dec-03 Jun-04 Dec-04 Jun-05 Dec-05 Jun-06 Dec-06 Jun-07 Dec-07 Jun-08 Dec-08 Jun-09 Mar-10

Emerging MarketsInternational EquityLarge GrowthLarge ValueMid GrowthMid ValueSmall GrowthSmall ValueInternational BondsUS BondsCash

CashUS

BondsI nternational

BondsSmallValue

SmallGrowth

MidValue

MidGrowth

LargeValue

LargeGrowth

I nternationalEquity

EmergingMarkets

Fund 2.01 0.03 0.99 2.06 4.14 1.49 16.38 29.10 36.17 3.74 3.88

Consistency of Style: Average Style Exposure - Trailing 60 Months

For more specific performance of the options available within your plan, please see the plan level performance summary at the end of this document.Data supporting the complete fund evaluation process is available upon request.

Upside MarketCapture %

Peer GroupMedian

103.89 99.97

Downside MarketCapture %

Peer GroupMedian

99.56 101.22

5 Year AnnualizedStandard Deviation

Peer GroupMedian

16.39 16.43

5 Year AnnualizedReturn

Peer GroupMedian

2.80 1.79

ING Fund Evaluation Scorecard provides a meaningful comparison of a fund'shistorical performance relative to its appropriate peer group.

According to Wilshire, theING Fund EvaluationScorecard is an appropriateand sound fiduciaryassistance tool that reflectsan analytical evaluationprocess that is fair, sound,prudent and consistent withindustry norms.


To Support Investment Option Selection and MonitoringUnder the ING Life Insurance and Annuity CompanyRetirement Platform

ING Life Insurance and Annuity Company (“ING”) has engaged Wilshire Associates Incorporated (“Wilshire”)to evaluate ING’s Fund Evaluation Scorecard fiduciary assistance tool (the “Scorecard”).

Wilshire Certification

Wilshire® has conducted a comprehensive, independent review of the ING Fund Evaluation Scorecard. Based on thatreview, Wilshire certifies the Scorecard as an appropriate and sound fiduciary assistance tool and reflects ananalytical evaluation process that is fair, sound, prudent and consistent with industry norms.

The Scorecard facilitates the fund selection and monitoring process by (1) analyzing the characteristics of the fundsinvestment options provided on the ING Platform; (2) comparing funds within available asset classes; and (3) ratingeach fund on a scale of one through 10, with 10 being the highest possible score. The Scorecard uses a purelyobjective process. A set of standardized criteria is applied to all investment options on the platform with at leasta three-year track record available. Its analysis covers five broad perspectives:• performance,• risk,• risk-adjusted performance,• consistency of style, and• expenses.

Within each category, the Scorecard process evaluates the fund against the external universe of similarly managedfunds of like class structures (or peer group). All funds are evaluated using historical data going back to fundinception or 10 years, whichever period is longer.

Important Disclosures

1. ING pays an annual service fee to Wilshire to compensate Wilshire for its services. ING also indemnifies Wilshire for any claims against Wilshire arisingout of this Certificate, subject to standard commercial exceptions for gross negligence or willful misconduct.

2. Scorecard is intended for use by plan sponsors and their fiduciaries as a resource for evaluating the investment options available on the platform.The choices available on the platform allow you to select from among various combinations of available investment options as the menu for the Plan.The selection of particular investment options should properly reflect fiduciary consideration of a number of factors, many of which are individualizedto the Plan, in addition to the Scorecard resource. Neither Wilshire nor ING is rendering investment advice with respect to the Plan’s selection; theselection and ongoing monitoring of investment options will be performed by the Plan’s fiduciaries. Wilshire Associates is not a member of the INGfamily of companies. Wilshire is a registered service mark of Wilshire Associates Incorporated, Santa Monica, California.

Wilshire Funds Management uses mathematical and statistical investment processes to allocate assets, select managers and construct portfolios and funds in ways thatseek to outperform their specific benchmarks. Past performance does not guarantee future returns, and processes used may not achieve the desired results.

ING FUND EVALUATION SCORECARD

www.ing-usa.com www.ingretirementplans.comInsurance products, annuities and funding agreements issued by ING Life Insurance and Annuity Company ("ILIAC"), One Orange Way,Windsor, CT 06095, which is solelyresponsible for meeting its obligations. Plan administrative services provided by ILIAC or ING Institutional Plan Services, LLC. Securities distributed by or offered throughING 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 byING Financial Advisers, LLC. Variable annuities issued by ReliaStar Life Insurance Company of New York are distributed by Directed Services LLC. Only ING Life Insurance andAnnuity 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 familyof companies. Products and services may vary by state and may not be available in all states. © 2009 ING North America Insurance Corporation. C09-0626-075 (7/09)

3010999.X.S (7/09)

ING FUNDEVALUATIONSCORECARD

CERTIFICATIONIndependently Certified by Wilshire Funds Management, A Business Unit of Wilshire Associates Incorporated

For Plan Sponsor Use Only

“Wilshire“ is a registered service mark of Wilshire Associates Incorporated, Santa Monica, California.WilshireFunds Management uses mathematical and statistical investment processes to allocate assets, select managersand construct portfolios and funds in ways that seek to out perform their specific benchmarks. Past performancedoes not guarantee future returns, and processes used may not achieve the desired results. ING and its companiesare not affiliated with the Wilshire family of companies and receive no fee or other direct financial benefits fromWilshire in connection with the use of its services.

ING pays an annual fee to Wilshire to compensate Wilshire for its services. ING also indemnifies Wilshirefor any claims against Wilshire arising out of this Certificate, subject to standard commercial exceptions for grossnegligence or willful misconduct. Neither Wilshire nor ING is rendering investment advice with respect to thePlan’s selection; the selection and ongoing monitoring of investment options will be performed by the Plan’sfiduciaries.Wilshire Associates is not a member of the ING family of companies.Wilshire is a registered servicemark of Wilshire Associates Incorporated, Santa Monica, California.

3016103.C.S 11 (7/10)

Portfolio Blueprint® –a fiduciary support programavailable from MorningstarAssociates, LLC.

In today’s demanding regulatory andinvestment environment, plan you mustdo everything in your power to ensureyour retirement plan offers employeesan appropriate menu of investmentoptions. It’s a tall order for mostemployers like you to handle on yourown. That's why ING has joined forceswith Morningstar Associates to offeryou as a plan sponsor of a definedcontribution retirement program asimple and objective solution.

Portfolio Blueprint provides you withfund recommendations, built byinvestment professionals atMorningstar Associates, suitable fortheir plan’s characteristics andemployee demographics. In addition,Morningstar Associates will monitor therecommendations on an ongoing basis.You benefit from MorningstarAssociates' acknowledgement offiduciary responsibility for theirinvestment advisory services.

Under ERISA, employers are generallyfiduciaries of their retirement plansand are required, among other things,to operate the plan solely in the bestinterests of participants, prudentlyselect investments, avoid conflicts ofinterest, and monitor investmentoptions on an ongoing basis.

With Portfolio Blueprint,Morningstar Associates offers youinvestment expertise andacknowledges its role as a fiduciary,as defined in Section 3(21)(A)(ii) ofthe Employee Retirement IncomeSecurity Act of 1974 ("ERISA"), withrespect to the selection andongoing monitoring of the plan'sinvestment menu. Plan sponsorsare solely responsible fordetermining whether the programis appropriate for the plan.

ING Portfolio Blueprint brings together ING’s global leadership in thedefined contribution market and Morningstar Associates’ expertise inplan lineup construction along with their reputation for objective,insightful investment analysis.

• Morningstar Associates takes on an ongoing commitment for selectingand monitoring investment options and producing reports

• The Workforce Profiles created by Morningstar Associates provide aconvenient and systematic way to help you identify the ideal assetcategories for your plan

• Morningstar Associates’ category-based approach and access toMorningstar, Inc.’s databases creates a level of diversification that’sdifficult to duplicate

• Leverage the reputation and brand of both Morningstar and ING toaddress many of the challenges you face today

Portfolio Blueprint MakesYour Fiduciary ResponsibilitiesEasier to Manage

As part of the Portfolio Blueprintservice, you will receive:• Investment selection from anobjective third party, eliminatingpotential conflicts of interest

• A fully diversified menu ofinvestment options including bothproprietary and third party funds

• A customized Investment PolicyStatement that can be added to theplan documents

• Ongoing monitoring and duediligence of investment options by aleader in fund analysis

•Morningstar Associates’acknowledgement of its role as afiduciary with respect to theselection and ongoing monitoringof the Plan’s investment menu.


Through a strategic relationship withMorningstar Associates, LLC, aregistered investment advisor andwholly owned subsidiary ofMorningstar, Inc., ING makes availablePortfolio Blueprint®, a service offeringinvestment solutions and fiduciarysupport from Morningstar Associatesfor plan sponsors. MorningstarAssociates makes its fund selectionsfrom the fund platform that isavailable under the applicable INGproduct, which is a subset of thebroad fund universe. The fundplatform includes both proprietary andnon-proprietary funds. Only INGproprietary options are made availablein the money-market and stable-valuecategories. ING may at times requestthat Morningstar Associates reconsiderspecific fund selections but the finaldecision on which funds are selectedfor Portfolio Blueprint is MorningstarAssociates’. The Morningstar nameand logo are registered marks ofMorningstar, Inc. All other logos andmarks are the property of theirrespective owners. ING and itscompanies are not affiliated with theMorningstar family of companies andreceive no fee or other direct financialbenefits from Morningstar inconnection with the use of its services.

3016103.C.S 22 (7/10)

How the Program Works

A unique advantage of PortfolioBlueprint is the ease with whichyou can get started in the program.Materials created by MorningstarAssociates can help you documentthat you fulfilled your fiduciaryresponsibility for fund selection.

Below are the main steps thatwill guide you through the process.• Choose Your Profile: Choose theWorkforce Profile that best fits thecharacteristics of your retirementplan.

• Select Your Lineup: The selectedWorkforce Profile will guide you to aRecommended Fund Menu.Working with your financialprofessional, select the best fundsfor your plan lineup from this menu.You will also be provided with acustomized Investment PolicyStatement for your plan.

• Sign Up: Review and execute thePlan Sponsor Agreement – whichdescribes your obligations and theobjectives of MorningstarAssociates, including its role as afiduciary – to enroll in the program.

• Review Reports: Once youimplement the plan lineup,Morningstar Associates producesquarterly reports to help you stay ontop of your plan monitoringresponsibilities. You must check theING Plan Sponsor Web site eachquarter to review these reports.

•Monitor Notifications and MakeUpdates as Necessary:Morningstar Associates may, fromtime to time, make changes to theRecommended Fund Menu. You willbe notified of these changes andwill have approximately six monthsto make changes to your planlineup. If you choose not toimplement the changes, the servicewill be cancelled and the fiduciarysupport will be discontinued.

1

3

4

5

Choose a WorkforceProfile

Select investments fromthe Recommended FundMenu

Sign the ContractualAgreement

Review Reports Providedby MorningstarAssociates

Monitor Notifications

2

4.Custo

mized

Employee

Communicatio

ns&Tools

ING’s customized employee communicationsand behavior-changing tools help educate, guideand motivate employees to take full advantageof plan benefits.


3016103.C.S 12 (7/10)

CUSTOMIZED EMPLOYEE COMMUNICATIONS & TOOLS

ENROLLMENT MADE EASIER

Enrollment is the period that offersyou the best opportunity to promoteyour plan. Successful enrollmentcommunications can lead to increasedplan participation. Our goal duringthis period is to provide education toyour employees about investmentchoices so they feel more confidentwith their decision to enroll. How wedo this is through the “Your Number”Employee Education Experience.

Our “Your Number” EmployeeEducation Experience is based onING's popular “Your Number”national campaign.

Education/Enrollment

ING’s Education/Enrollment Specialistsprovide face-to-face education to youremployees about the specifics of yourplan and the importance of saving forretirement. Our Specialists offer avariety of expertise that includes:• Experience communicating all typesof plan features

• Experience working with diverseemployee populations with varyingdegrees of interest and knowledgeabout saving and investing

The enrollment presentation is basedon ING’s popular “Your Number”approach to saving for retirement.The goal of the presentation is to helpemployees understand the importanceof saving, the value of the plan, andhow saving through the plan mayhelp them get closer to achievingtheir own personal number—or theamount of money they need toretire the way they will want.

Enrollment Campaigns

ING’s “Your Number” enrollmentcampaigns are designed to motivateyour employees to take a proactiverole in their retirement planning.The campaigns take a unique andcreative approach to employeecommunications, creating a sense ofexcitement around the concept ofenrollment. Available campaignmaterials include posters, payrollstuffers, e-mails and Flashpromotions.

Customized Enrollment Guide

The “Your Number” Enrollment Guideencourages employees to take thefirst step toward their own retirementpreparedness by finding their“number” – or the total amountindividuals need to accumulate by thetime they retire. The Guide helpsindividuals calculate their number andestablish a savings and investmentstrategy through their plan to reach it.

The Enrollment Guide features:• Customization with your company’sname, logo, welcome letter andemployer match (if appropriate)

• Your Number Worksheet helpsemployees easily calculatetheir number

• Information about how to choosean investment strategy

• Account access instructions for theInternet and toll-free phone line

• Fund fact sheets for all availableinvestment options

• Disclosure material detailing relatedplan charges and expenses

The big issues withemployee retirementsavings today:*

• Workers have littleconfidence about havingenough

• – Only 6% of workers saythey are very confident ofhaving enough money tolive in retirement

• They don’t know howmuch is enough

• – Only 46% of workersreport they and/or theirspouse have tried tocalculate how much theywill need for acomfortable retirement

• They haven’t savednearly enough

• – 54% of workers reportless than $25,000 in totalsavings and investments

• Workers are counting ontheir retirement plan

• – 43% or workers expectan employer-sponsoredretirement savings plan tobe a major source ofretirement income

The key to a successful retirement program is employee participation.The key to participation is utilizing an engaging and informative employeecommunication strategy that helps maximize the value of the benefitsyou provide. For that reason, an ING Client Relations Manager will workclosely with you to develop a strategy that meets the needs ofyour organization and your employees.

ING's strategy focuses on key areas including Enrollment, Guidance,Education, and Information and Communication

* 2010 Retirement Confidence Survey, EmployeeBenefit Research Institute, March 2010

ING “Your Number” Campaign basedon ING’s popular national campaign

Enrollment

Employees can quickly and easily enrollin the plan by logging onto ING’s onlineEnrollment Center. Intuitive navigationand simple prompts guide usersthrough the steps of enrollment withclarity and ease. A confirmation ofenrollment will be mailed directly to theemployee’s home.

For those employees without access tothe Internet, enrollment by form orphone is also available.

Automatic Enrollment andDeferral Increase

To eliminate employees’ feelings ofconfusion and being overwhelmedabout enrolling in the plan, you canchoose to “automatically enroll” newlyeligible (and in some cases, current butnot participating) employees into their401(k) plan. Employees no longer needto actively choose to participate, how toinvest, where to invest or fill out forms.

Auto-enrollment addresses employees’tendency to procrastinate by makingNOT participating the active choice.

Options for how sponsors can directcontributions include:• Contributions can be directed toan asset allocation fund

• Any combination of funds within theplan, in any percentage you choose,can also be chosen for an automaticenrollment investment

• Any single fund within the plan canbe selected

The employee-initiated contributionrate escalator feature can helpparticipants continue to grow theirretirement savings by automaticallyincreasing contributions each year.When a participant elects this feature,contributions will increase by adetermined percentage annually untilreaching a percentage limit. Once thatlimit is reached, the participant isresponsible for increasingcontributions further.

Automated Eligibility Monitoring*

ING also monitors the status of youremployees and automatically notifiesnewly eligible employees of theiropportunity to enroll in the plan. Thisfully-automated plan feature helps toboost plan participation on anongoing basis.

INGInstitute forRetirementResearch

www.ingretirementresearch.com

At ING, we are dedicated tohelping participants obtain amore secure financial future bymaximizing the benefits oftheir employer-sponsoredretirement plan. The INGInstitute for RetirementResearch is a part of ourorganization committed to thestudy of participant investmentbehavior and the developmentand promotion of solutionsthat help participants improvetheir retirement savings. TheInstitute offers an extensivereference library on topics suchas the Psychology of Investing,Adult Learning Theory andRedefining the EnrollmentExperience. The Institute alsorelies on its leading-edgeresearch to develop behavior-changing employee solutionsthat take advantage of normalhuman emotion andpsychologically-driven behaviorin a multiple touch pointstrategy.


The Enrollment Guide

To view a demo of our online enrollment center, visitwww.ingretirementplans.com/enrollmentdemo1

* Available for full service plans with $3M in assets.

GUIDANCE MADE EASIER

Investment Advisory Services fromMorningstar AssociatesING has aligned with MorningstarAssociates to offer Morningstar®

Retirement ManagerSM – a range ofinvestment advisory services designedto meet the needs of all yourparticipants. Whether yourparticipants prefer to have theiraccount professionally managed or useMorningstar Associates’ resources tomake more informed decisions,Morningstar Associates can help makeit easier for your participants tomanage their retirement account.

Participants will receive a personalizedretirement strategy includingrecommendations for their:• Target retirement income goal• Savings rate• Asset mix• Investment selection• Handling company stock(if applicable)

Retirement Manager’s easy-to-usethree step process means participantscan get their retirement strategyquickly.

Education and Research

Participants looking for more in-depthresearch or education to help themmake decisions can access RetirementManager’s research and educationmodules to pull detailed, world-classresearch reports about the investmentoptions available to them as well aseducational articles about a variety ofinvesting and financial planning topics.

Personalized to the Participant

Morningstar Associates considersall relevant plan rules and fundrestrictions and adjusts its fundrecommendations if the participantprovides information about outsideassets, preferences to excludeparticular funds, or otherpersonal data.

Services Available throughMorningstar Retirement ManagerManaged by You (Advice)For participants who take an activerole in managing their retirementaccounts, Morningstar Associatesprovides self-directed servicesdesigned to help defined contributionplan participants make more informedinvestment decisions. Based on theparticipant’s specific investmentaccounts, financial goals, and risktolerance, Morningstar Associates actsas the investment advisor and providesa personalized retirement strategyincluding a retirement income goal,recommended savings level, portfolioconstruction, and recommendationsfor the most appropriate investments

for that individual’s retirementaccount. With Managed by You(Advice), plan participants have theability to receive fund-specificrecommendations while simulating theimpact of different risk levels oninvestments. The participant cansubmit their allocation instructions viaRetirement Manager rather thanhaving to manually execute themthrough the recordkeeper’s Web site.

Morningstar Associatesseeks to give employees theadvice they want and need.

Morningstar® Retirement ManagerSM

Helping Your RetirementPlan Participants Plan ForRetirement


Plan Sponsor Use Only

Morningstar® Retirement ManagerSM

Key Benefits of Morningstar®

Retirement ManagerSM:• Reduce fiduciary risk – MorningstarAssociates, LLC, a registeredinvestment advisor, acceptsfiduciary responsibility for theadvice it provides.

• Improve benefits offering - You canhelp improve the competitiveness ofyour benefits package by offeringprofessional investment advice froman independent, objective,investment expert with a widely-recognized and trusted brand name,Morningstar.

• Improve overall plan metrics –Retirement Manager helps make iteasier for plan participants tomanage their retirement accountsby helping them answer the twomost common questions about theirretirement plan: How much should Isave? Which investments should Ichoose? This can result in higherparticipation and deferral rates andmore appropriate asset allocations.

Additional benefits include:• Helps your participantsmeet their retirement objectives

• Meets a wide-range ofemployee needs

• Provides access to institutional-quality investment advice

Personalized Retirement Strategy from Morningstar


Morningstar has designed a strategy to maximize your ability to reach your retirement goals. Learn more about ourproposed changes to your savings, asset mix, and investment strategies.

Obtain more details, adjust your personal data, or implement your proposed strategy athttp://www.ingretirementplans.com.

Saving more now is one of the most effectiveways to increase your future retirementincome and meet your goals. Morningstarproposes that you raise your total savings asmuch as possible based on your situation.

Current information not available. Increase your total savings as muchas possible based on your situation.

Morningstar believes a relatively heavyconcentration in stocks will result in anappropriate asset allocation strategy for you,based on the available information. You canachieve this proposed strategy simply byadjusting your investments as described in thenext section. While stocks present a greaterchance of volatile ups and downs in yourp f li k h i d i

BalancedAsset %

Large Cap Stock 45Mid/Small Cap Stock 10International Stock 4Bonds 20Cash Equivalents 21

100

AggressiveAsset %

Large Cap Stock 39Mid/Small Cap Stock 17International Stock 27Bonds 17Cash Equivalents 0

100

B

NameJohn Smith

AccountsING 401(k)

Created On04-28-2009

Reference ID147409

Page1 of 3

©

Managed by Morningstar(Managed Accounts)The managed accounts service is mostbeneficial for participants who don’thave the time, interest or knowledgeto manage their retirement accountson their own. With the managedaccounts service, the participantassigns to Morningstar Associates theresponsibility for managing theirretirement plan assets. Incorporatingpersonal information about eachparticipant, they use their fundselection and asset-allocationexpertise to create individual,diversified retirement portfolios fromthe investment options available inthe plan.

On a quarterly basis, MorningstarAssociates reviews the participants’portfolios and rebalances eachaccount as necessary. The benefit tothe participant is knowing that aprofessional investment manager isimplementing a completelycustomized strategy for theirretirement account and overseeing iton an ongoing basis. MorningstarAssociates serves as the discretionaryinvestment manager, providing fundselection, asset-allocation strategy,fundamental portfolio engineering,ongoing monitoring, and rebalancing.As a result, Morningstar Associatesassumes fiduciary responsibility for theinvestment advice it provides toparticipants.

IMPORTANT: The projections or otherinformation generated byMorningstar® Retirement ManagerSM

regarding the likelihood of variousretirement income and/or investmentoutcomes are hypothetical in nature,do not reflect actual results (includinginvestment results) and are notguarantees of future results. Resultsmay vary with each use and over time.

Morningstar Retirement Manager isprovided by Morningstar Associates, LLC(“Morningstar Associates”), a registeredinvestment advisor and a wholly ownedsubsidiary of Morningstar, Inc., and isintended for citizens and legal residents ofthe United States and its territories.Morningstar Associates’ advisory servicerelates solely to the investment optionsoffered under the plan. Retirement planfunding products are offered through INGFinancial Advisers, LLC (member SIPC) orother broker dealers with which it hasselling agreements. ING providesMorningstar Associates with the plan’sinvestment options and information aboutparticipants but the decisions regardingthe advice provided are made byMorningstar Associates. ING and itscompanies are not affiliated withMorningstar Associates or its affiliates,and receive no fee or other direct financialbenefits from Morningstar Associates inconnection with the use of its services. TheMorningstar name and trademarks are usedunder license from Morningstar Associates.

ING’s proven and tested transition strategy helps ensure employess recognize,understand and appreciate enhanced plan features and benefits.

• Annual anniversary of enrollment• Missing employer match• Participant stops contributing tothe plan

Available in multiple delivery options,such as posters, e-mail, payroll stuffersand Flash promotions, these materialscan be selected and customized toachieve maximum behavior-changing results.

Online and OnsiteEmployee Education

Our library of informative employeeeducation programs and seminarsrequire no work or cost to you.Depending on your plan, we offerperiodic onsite workshops for youremployees. Access to theseinformative financial seminars is alsoavailable online. Your employees canlisten to and follow prerecordedpresentations complete withworksheets designed to advancetheir knowledge and help them makemore informed financial decisions.Seminar topics include retirementreadiness, investing 101, retirementsavings options, and budgeting.

Online Financial Resource Center

Participants can access educationalinformation about planning forretirement, investing and personalfinance through the Financial ResourceCenter located on the ParticipantWeb site. Available to participants24-hours-a-day, seven-days-a-week,the Financial Resource Centerempowers your employees to planfor their retirement when it’s mostconvenient for them. Here,participants can:• Access online financial calculators tocreate personalized illustrations

• Create a customized library ofretirement planning and investmentresources

• Personalize an educationale-curriculum based on individualneeds, interests and knowledge level

• Access print, audio and video itemsthat best match their interest andknowledge level


“Save, Invest, Spend” Campaign – asample targeted, customized participanteducation campaign

EDUCATION MADE EASIER

At ING, we believe that ongoingeducation is the key to helpingparticipants improve their retirementplan savings. Our comprehensivefinancial education program deliversvaluable, easy-to-understandinformation to your employees inmultiple ways.

Targeted and CustomizedParticipant Campaigns

Various events can spark opportunitiesfor communicating the importance ofsaving more toward retirement to yourparticipants. ING’s series of campaignscan be customized to yourorganization’s specifications and used totarget participants during key events.For example, a deferral increasecampaign could motivate participants tosave more under these circumstances:• Raise time• Loan payoff• Age 50 (Catch up)

Chart your progressPeriodically, check in with your savings progress.My Retirement Outlook is available online at yourPlan’s Web site tohelp you chart youraccount's growthpotential. Visit yourPlan's Web site andselect "My RetirementOutlook" on thelogin page to accessthis tool.

An additional contribution of 10 years 20 years 30 years$10/month could add up to… $1,801 $5,5690 $14,086$20/month could add up to… $3,602 $11,380 $28,171$50/month could add up to… $9,005 $28,450 $70,430$100/month could add up to… $18,010 $56,900 $140,860

Assumes 8% rate of return and contributions made at the end of each month. Thisillustration is hypothetical, is not guaranteed, and is not intended to reflect theperformance of any specific investment. The tax-deferred investment will be subjectto taxes on withdrawal. Systematic investing does not ensure a profit nor guaranteeagainst loss.

Can you picture it?Your Plan encourages you to think about your futuregoals and to create a plan to achieve them. To increaseyour contribution rate, visit the Plan's Web site orcontact an ING Customer Service Associate. Plan accessinformation is shown on the left.You can request a password reminder using the link onthe Login page in the Plan Web site or by calling theCustomer Contact Center.

3015913.C.P (4/10) © 2010 ING North America Insurance Corporation. C10-0423-011R (4/10)

Kick it up a notchWhenever you can, you should try to increase yourcontribution rate. Even just 1-2% more each year couldmake a big impact down the road.

Not FDIC/NCUA/NCUSIF Insured Not a Deposit of a Bank/Credit Union May Lose Value Not Bank/Credit Union Guaranteed Not Insured by Any Federal Government Agency

You should consider the investment objectives, risks, charges and expenses of the investment optioncarefully before investing. The prospectuses/prospectus summaries/information booklets containing thisand other information can be obtained by contacting your local representative. Please read theinformation carefully before investing.

Plan WebsitePlan Phone


Variable text optionVariable text optionVariable text optionVariable text option

Variable Headline Option

BANK OR SPONSOR LOGO

Insurance products, annuities and funding agreements issued by ING Life Insurance and Annuity Company (“ILIAC”), One Orange Way, Windsor, CT 06095, or annuityproducts are issued by ReliaStar Life Insurance Company, each of which is solely responsible for meeting its obligations. Plan administrative services provided by ILIAC orING Institutional Plan Services, LLC. All companies are members of the ING family of companies. Securities distributed by or offered through ING FinancialAdvisers, LLC (member SIPC) or other broker-dealers with which it has a selling agreement. Only ILIAC is admitted and its products offered in the State ofNew York.Agent of ReliaStar Life Insurance Company (Minneapolis, MN). Registered Representative of ING Financial Advisers, LLC (Windsor, CT) (member SIPC).

Non-Affiliated Text

Plan Name

Communicate the enhanced plan benefits and featuresthrough informative and easy to understand communications.

PLAN AND INVESTMENT SELECTIONS

EMPLOYEE COMMUNICATIONS

Employee EducationTransition Brochure

The above specimen notice is not intended as tax or legal advice. Modifications may be required to meet our plan’s particular needs.

Please consult with your plan’s tax advisor and legal counsel.

Important Information about Your Company’s Retirement Plan

“Your Company Name” (your “Employer” or “we”) recently selected ING Life Insurance and

Annuity Company as the new investment and service provider for the “Plan Name” (the

“Plan”). All record keeping services will be transferred to ING and all amounts in the

investment vehicles currently available under the Plan will be transferred to new investment

options offered through ING, beginning effective “date”. A conversion period will make this a

successful and seamless transfer, and ensure the accurate and complete transfer of your account

and Plan records from our current service provider.

During the conversion period we must undertake several steps to transfer services and plan

assets to ING. Our current provider must finalize our records by completing all transactions

currently in process, balance the Plan and forward the records to ING. Then, ING must update

its record keeping system for our Plan provisions, the enrollment record for each participant,

and the transaction records supplied by our current service provider. In addition, ING must

receive and allocate our plan assets to the new investment options (as we direct) and balance

the records to the assets it receives for our Plan.

This conversion process will begin the week of Sunday,00/00/0000, and end the week

beginning Sunday, 00/00/0000 (timeframe provided should be approximately four to six

weeks). During the conversion period your deferred contributions will continue to be deducted

from your paycheck and invested according to your direction. However, to establish accurate

records and fund balances with ING, during this period no other individual account

transactions can be processed either through our current provider or through ING. This is

referred to as a “blackout period”. Specifically during the blackout period, you will not be

permitted to:

• Request a distribution of Plan assets;

• Request a loan;

• Change allocations / Transfer assets from one fund to another;

• Rollover assets to or from another plan to this Plan or;

• Transfer assets to or from another plan to this Plan;

• Access your account for inquiry purposes, either online or via the 800#

During the beginning week and ending week of the blackout period you may contact (plan

administrator must provide toll free number or website and provide specific information for

accessing it) with questions regarding the exact date the blackout period will begin and end.

EMPLOYEES ARE TRANSITIONED

Maps to New FundsCurrent Funds

3015912.C.P (5/10) © 2010 ING North America Insurance Corporation. C10-0528-003R (6/10)

The key is compoundingWhen you invest through your employer’s retirementPlan, the return you make on your money is automaticallyreinvested. The longer you have to invest, the greater theopportunity for your investments to grow. So start now!

Can you picture it?Your Plan encourages you to think about your futuregoals and to create a plan to achieve them. Enroll todayto begin saving for your own picture of retirement.Simply follow the instructions below.

Chart your progressPeriodically, check in with your savings progress.My Retirement Outlook is available online at yourPlan’s Web site tohelp you chart youraccount's growthpotential. Visit yourPlan's Web siteand select “MyRetirement Outlook”on the login page toaccess this tool.

Not FDIC/NCUA/NCUSIF Insured Not a Deposit of a Bank/Credit Union May Lose Value Not Bank/Credit Union Guaranteed Not Insured by Any Federal Government Agency

You should consider the investment objectives, risks, charges and expenses of the investment optioncarefully before investing. The prospectuses/prospectus summaries/information booklets containing thisand other information can be obtained by contacting your local representative. Please read theinformation carefully before investing.

Look how $10,000 can grow with compounding

$40,000

$30,000

$20,000

$10,000

$0Years 0 5 10 15 20 25

Initial investment

Investment +compounded growth

$42,919

$32,071

$23,966

$17,908

$13,382

This hypothetical illustration is not guaranteed and is not intended to reflect theperformance of any specific investment. The tax-deferred investment will be subject totaxes on withdrawal. It assumes a principal amount of $10,000 made at the beginningof year 1, with no other annual additional principal. An effective annual rate of 6% isapplied. Systematic investing does not ensure a profit or guarantee against loss.

Online Customized andTargeted Messaging

Through ING’s Participant Web siteMessage Board, Participants receivemeaningful messages and alerts thatencourage them to take action.Sophisticated technology enables us todeliver targeted messages directly toimpacted participants. Personalizedmessages including information aboutcompany matches, beneficiaryinformation and catch-upcontributions provide participants withthe information they need to makeinformed decisions about their plan.

Transition Counseling

People change jobs, retire or maybecome the beneficiary of a lovedone’s retirement plan assets. At noadditional cost, a staff of investmentspecialists at ING can provide yourparticipants with the information theyneed to:• Understand their options• Know their rights• Save and invest with confidence

New plan participants are offeredthe convenience of consolidatingemployer-sponsored plan assets intoa single plan. In addition, rolloverIndividual Retirement Accounts (IRAs)are available to provide theopportunity for continued tax-deferredinvesting. When your employees areready to retire, your local retirementprofessional will provide them withinformation about the variousdistribution options available,including a calculation of monthlyretirement benefits. We help makesure that all of your employees havethe information they need to makeeducated decisions.

MULTICULTURAL COMMUNICATIONS

As diverse as the products and serviceswe offer, so are the customers weserve. We believe diversity is morethan an ideal – it is our mission andwe are committed to effectivelyserving the markets in which we liveand work. Our participantcommunications are designed to caterto diverse customers needs.

We work to understand the uniquedifferences, thinking styles andperspectives of our customers. Inresponse, and have developed acomprehensive multicultural strategythat focuses on education ofmulticultural employeepopulations including:• Comprehensive, educationalcommunications using in-cultureand in-language material

• Dedicated support and serviceincluding:– Onsite financial literacy workshops,delivered in-language addressingcommon financial concerns amongmulticultural employee populations

– Cultural sensitivity training forexecutives, managers and humanresource personnel

– Bilingual call center capabilities forstreamlined, effective customerservice

– Marketing library of multiculturaltools and resources availableonline via ING’s Web site

INFORMATION ANDCOMMUNICATION MADE EASIER

ING offers a number of ways for youremployees to access information, talkto an ING representative or learn moreon their own. They can reach us whenthey want, how they want and wherethey want – the choice is theirs.

Quick Account Information

ING’s 24-hour,* toll-free number andParticipant Web site allowsparticipants to manage their accountssecurely, quickly and easily – with justa phone call or the click of a mousewhen it is most convenient for them.Here, participants can:• Obtain account balance andunit values

• Request forms• Update investment electionsand allocations

• Change contribution amounts• View fund performance andquarter-end statements

• View personal rate of return

ING’s employee communications includein-culture and in-language material for

multicultural employee populations.

* Except for scheduled downtime for maintenance.

ING's Partcipant Web Site

Participants can monitorand manage theirretirement plan account24/7 using ING’sParticipant Web site.

This powerful, yet easy-to-use tool provides participantswith total control over theirplan account. Site featuresinclude such features as:

• Targeted and customizedmessage board

• Personalized Market WatchTool that can becustomized to includepreferred ticker symbols

• Financial Resource Centerthat features personalizedonline financial education

El costo queimplica esperarComience hoy a ahorrar

Una buena regla general es ahorrarsuficiente dinero para asegurarse de queva a vivir como siempre ha vivido. Noespere que tendrá menos gastos en susaños dorados que los que tiene ahora.La mayoría de los asesores financierosestán de acuerdo en que necesitará de70 a 80 por ciento más del ingresoprevio a la jubilación para mantener suestilo de vida durante esos años.

Tenga también en mente que el costo dela vida durante la jubilación sigueaumentando, ya que el costo de laatención médica, vivienda, energía yotros costos también aumenta. Además,no subestime el poder de la inflación, yaque incluso una inflación baja puededañar el poder adquisitivo de los dólaresque tiene ahorrados para su jubilación.Por ejemplo, si usted estima una tasa deinflación del 3% durante los próximos25 años, un galón de leche que comprehoy a $4,29 le costará $8,37 en 2031.

Así que aunque sus gastos en el mejorde los casos se mantengan iguales, oincluso aumenten, no puede esperar que

ocurra lo mismo con su ingreso. Esa es larazón por la que cada día que pasa queusted no ahorra es otro dólar queprobablemente no tendrá para sujubilación.

Ahorre ahora, pague después

Una de las mejores y más sencillasmaneras de comenzar a ahorrar es sacarprovecho del plan de jubilaciónpatrocinado por su empleador, como losplanes de compensación diferida 401(k),403(b) o 457. Y si usted está preocupadode si puede pagarlo, tenga en mente queestos planes pueden ahorrarle dineroahora y más adelante. Funciona así:

• Menos impuestos hoy: Los aportes a suplan se hacen antes de las deduccionesdel impuesto sobre el ingreso, lo quesignifica que está pagando menos enimpuestos actuales con cada chequede pago.

• Menos impuestos mañana: Su cuentacrece con impuestos diferidos, lo quesignifica que usted no paga impuestossino hasta que retire los fondos del plan.Debido a que lo más probable es que enese momento usted estará en un rangoimpositivo menor, pagará menosimpuestos que lo que pagaríaactualmente. (Nota: Pueden aplicarsemultas a los retiros anticipados,usualmente antes de los 59 ½ años).

¿Ya empezó a ahorrar para sujubilación? ¿Piensa que ustedestará bien si comienza a ahorrarmañana? ¿o el mes próximo? ¿o elpróximo año? Piénselo de nuevo.Ahorrar aunque solo sea unpequeño monto cada mes puedehacer una gran diferencia cuandoesté listo para jubilarse. Entonces,¿por qué esperar? ¡Comience hoya ahorrar!

Más años, más dinero

La buena noticia es que, es muyprobable que usted viva más años quelas generaciones pasadas. La malanoticia es que, vivir más significa quenecesitará más dinero para su jubilación,posiblemente hasta por 30 años.Cualquiera sea su sueño para lajubilación, ya sea viajar por el mundo,jugar golf o simplemente estar tranquiloy disfrutar de los nietos, lo último quedesea es preocuparse porque no lealcanzará el dinero.

La familia de compañías de ING suministra esta información sólo para su conocimiento.

Informe Especial de ING

Su futuro. Más fácil.®Preparación para lajubilaciónCómo respaldar la visión que usted tiene desu jubilación

planificación adecuada, el vivir más de loque puedan rendir sus ahorros es unaposibilidad real. De modo que, ¿estálisto para jubilarse?

Vidas más largas, jubilacionesmás largasHoy en día la gente vive más que nunca.Esas son las buenas noticias. Las malasson que necesitará más dinero para sujubilación. La Sociedad de Actuariosinforma que un hombre de 65 añostiene una probabilidad del 50% dellegar a los 85 años, mientras que unamujer de 65 tiene una posibilidad del50% de llegar a los 88 años. Y que laprobabilidad de que al menos uno delos miembros de una pareja de 65 añosalcance una edad de 92 años es del50%.1

El intentar determinar qué tan larga serásu vida no es una opción realista. Sumejor opción es apostar a que vivirá másde lo que piensa, y tener en cuenta laposibilidad de que necesitará ingresospara su jubilación hasta que tenga 90años o más.

¿Cómo imagina que será sujubilación? Tal vez dará la vuelta almundo. O jugará golf. Osimplemente descansará y disfrutaráde sus nietos. Ahora pregúntesecómo va a convertir ese sueño enrealidad. ¿El camino que hoy transitale permitirá pagar para hacerrealidad el sueño de su jubilación?

“El futuro ya no es lo que eraantes”Yogi Berra, personaje legendario delbéisbol, podría haber resumido lo quesignifica la jubilación con esa citaoriginal y profunda. Para bien o paramal, la jubilación ya no es lo que eraantes. El retirarse a la edad de 65 añoscon un reloj de oro en el bolsillo ysentarse en una mecedora en el porchede la casa ya no es la situación máscomún para los jubilados.

Hoy en día muchos ven la jubilacióncomo una etapa de actividad y departicipación. El respaldar esa visión, noobstante, es otra cosa. Diversos factorespudieran poner en peligro sus metas deingresos durante su jubilación. Sin una

La familia de compañías de ING suministra esta información sólo para su conocimiento.

Los gastos pueden ser muycostososConforme a las pautas generales de lajubilación, sus ahorros deberánreemplazar entre un 70% y un 80% desus ingresos anteriores a la jubilación, enfunción de qué tan activo (o costoso)será el estilo de vida que planee para sujubilación.

Aunque algunos gastos podríandesaparecer al dejar de trabajar, otrosrápidamente los reemplazarán y podríanhasta ser mayores.

Usted puede probablemente despedirsede los gastos relacionados con sutrabajo, como la ropa de trabajo,almuerzos fuera de la casa, impuestosde nómina y aportes a los planes dejubilación. Pero tendrá muchos gastosnuevos, como viajes, pólizas de seguro ymedicamentos. Además, el 69 porciento de los estadounidenses quealcanzan la edad de 65 años necesitaránatención médica a largo plazo en algúnmomento de sus vidas2 –una cifra que seespera aumente con el paso del tiempo.

1 Fuente: Tabla de mortalidad anual del año 2000 ;Sociedad de Actuarios. Las cifras suponen que lapersona se encuentra en buenas condiciones desalud.

2 Asociación estadounidense de hogares y serviciospara la tercera edad, 2008.

Su futuro. Más fácil.®

Informe especial de ING

Custom Web Messaging

Speak With an ING RepresentativeFor answers to account questions notfound on the Participant Web site oron the automated voice responsesystem, ING’s dedicated team ofCustomer Service Associates areavailable via phone Monday to Friday8 a.m. - 9 p.m. (ET) to assist youremployees. Our highly-skilled CustomerService Associates understand thefeatures of your plan and are availableto answer questions, help withtransactions and provide qualityservice to all our customers.• Multilingual capabilities – CustomerService Associates are connected toa language line service that offersinterpreters for more than 100languages. A direct, toll-free line isavailable for Spanish-speakingparticipants.

• Services for the hearing/visionimpaired – ING uses AT&T’s Relay2000 Service to enable callers to beconnected with our direct serviceline and receive full translationservices from a variety of devices forthe hearing/vision-impaired.

Quarterly Statements

Quarterly account statements aree-mailed or mailed directly toparticipants’ homes and are a valuableresource for managing retirementinvestments. These comprehensivereports provide detailed informationregarding your employees’ accountactivity such as:• Account summary• Current asset allocations• Transaction detail• Investment performance• Contact information for help andadditional information

Newsletter

ING Pointers for Saving and Investingis an electronic newsletter thatincludes valuable financial educationarticles and encourages participantactions such as contribution increasesand diversification. Pointers isconveniently posted to the ParticipantWeb site and you can e-mail a link to anew issue of Pointers to youremployees each quarter.


Easy access to information

3016103.C.S 13 (7/10)

Continued on page 2

SAVINGS STRATEGIES SPRING 2010

Pointers THIS ISSUE• Be a Better Saver –Get into the Saving Habit

• Build Your Emergency Fund• Get the Most out of YourSocial Security Benefits

F O R S AV I N G A N D I N V E S T I N G

Be a Better SaverGET INTO THE SAVING HABITThe economic unrest of the last 18months has caused many of us tobecome more aware of our spendingand prompted us to think about savingmore: for retirement, the unexpected,homes, cars, college, and otherfinancial goals.

In a thesaurus, terms such as“scaling-down” “belt-tightening” andeven “cheap” come up as alternativewords for saving. The definition of“save” is more positive – “accumulate,”“set aside,” or “keep.” Both aspects arevalid – the difference is in which viewyou choose to take on saving. “Belt-tightening” can help and may be anecessity, but there are otherapproaches you can take to try to“accumulate” what you need to meetyour financial goals.

Save for the FutureSaving for a comfortable retirement isone of the most important financialdecisions you can make, and youremployer-sponsored retirement savingsplan is one of the best ways you cansave for your future. Automatic payrolldeductions make saving easy and as aPlan participant, your contributions aremade (in most cases) with pre-taxdollars reducing your taxable income.

Even better, your Plan offers a varietyof professionally managed investmentoptions, and earnings on yourinvestments are automaticallyreinvested so even small contributionscan keep your savings growing. Theremay additional saving incentivesavailable through your employer orfrom the Federal government whenyou save with your Plan as well.

Save for TodaySaving for the here and now is asessential as saving enough to fund yourretirement. It’s also important to havean emergency fund to handle theunexpected in addition to the moneyyou need for regular living expenses.And don’t forget to include money todo the things you and your family enjoy.

Saving takes discipline, but itdoesn’t have to be painful. As youget into the habit of saving andwatch your nest egg start to grow,you’ll have the incentive to stay onthe path to a more secure financialfuture for you and your family.

THE IMPORTANT STUFF HOW TO GET STARTED CONSIDER A CHANGE WHERE TO GET ANSWERS

Deposit your paycheckdirectly into your savingsaccount. Transfer only whatyou need to pay your billsto your checking account.

Once you’ve paid off a credit cardor loan, keep making thosepayments to yourself by puttingthe money into your savings.

Walk away from big purchases for atleast 24 hours, or even a week or two.You could end up finding a better price,or rethinking the purchase altogether.

Get into the habit of tossing yourspare change (or even dollar bills)into a jar every day. It’s an easything to do and adds up fast!

ThinkBeforeYou Buy

DirectDeposit

Treat YourSavingsas a Bill

SaveYourChange

Here are some suggestions that can help you get into the habit of saving.

Award-WinningCommunications

ING's employee communicationsare regularly recognized as some ofthe best in the industry by anumber of prestigious publicationsand associations. ING-producedcommunications received thefollowing awards:*

• Five first-place and three second-place Eddy Awards from Pensions& Investments

• Three Signature Awards fromProfit Sharing/401K Council ofAmerican (PSCA)

• Effective CommunicationLeadership Award and SpecialAward of Distinction fromNational Association ofGovernment DefinedContribution Administrators(NAGDCA)

• Best-in-Class Overall ParticipantEducation Program fromPLANSPONSOR Magazine

• Insurance and FinancialCommunicators Association(IFCA) Award

• Retirement Income IndustryAssociation Award for BestAdvertising for ING YourNumber from 401kWire.com.The award recognizes ads thatraise awareness of the need forretirement income and had alasting and memorable impressionon a viewer.

Pointers Newsletter

*Awards received in 2009-2010.

INGPO Box 990067Hartford, CT 06199-0067

Your Account Balance as ofDecember 31, 2009

$178,556.26

0000462520091231559261PART

October 01, 2009 - December 31, 2009Page 1 of 7

Your Current Investment MixStability of Principal 68%Global / International 13%Large Cap Growth 13%Large Cap Value 6%

Percentagesmay not be exactdue to rounding.

At Your Service:

>www.ingretirementplans.com>Customer Service: 1-800-584-6001Automated Voice Response System available 24/7Representatives available Monday thru Friday,8 a.m. - 9 p.m. ET>TDD (Hearing Impaired): 1-800-855-2880

Your Account SummaryAccount Balance on 10/01/2009 $174,258.58Your Contributions $676.69Withdrawals $0.00Investment Earnings $3,620.99Account Balance on 12/31/2009 $178,556.26Vested Balance $178,556.26

PLAN NAME

Location:

01-4447-AR-83A-010916228-0000001-0065037

At Your Service:>www.ingretirementplans.comINGPO Box 990067Hartford, CT 06199-0067>TDD (Hearing Impaired): 1-800-855-2880

>Customer Service: 1-800-584-6001Automated Voice Response System available 24/7Representatives available Monday thru Friday,8 a.m. - 9 p.m. ET


About YouHire DateAugust 15, 1991

About Your PlanPlanNumber

PlanType

XXXXXX 401K

Activity Statement for Your 401(K) Plan XXXXXXYour Current Investment Portfolio for Plan XXXXXX

Investment ObjectiveBalance on10/01/2009

TotalActivity

InvestmentEarnings

Balance on12/31/2009

Number ofUnits/Shares

Unit/SharePrice

Stability of PrincipalING FixedAccount $120,478.36 $676.69 $1,096.71 $122,251.76 N/A N/ALarge Cap ValueING T. Rowe Price Equity Inc -Svc $10,613.11 $0.00 $542.00 $11,155.11 1,011.1530 $11.0320Large Cap GrowthAmericanFunds Growth Fnd R4 $21,259.25 $0.00 $1,241.08 $22,500.33 2,469.5680 $9.1110Global / InternationalAmericanFunds EuroPacific R4 $21,907.86 $0.00 $741.20 $22,649.06 2,296.4070 $9.8628

Total $174,258.58 $676.69 $3,620.99 $178,556.26Unit/Share prices are displayed to four decimal places.

Allocation of Future Contributions for Plan XXXXXX

ING FixedAccount 100%

Total 100%

Activity by Source of Contributions for Plan XXXXXXBalance on10/01/2009 Contributions Withdrawals

InvestmentEarnings

Balance on12/31/2009

%Vested

EmployeePreTaxMatched $131,483.94 $676.69 $0.00 $2,732.09 $134,892.72 100.0%EmployerMatching $28,462.90 $0.00 $0.00 $591.48 $29,054.38 100.0%Profit Sharing 100%vested $14,311.74 $0.00 $0.00 $297.42 $14,609.16 100.0%Total $174,258.58 $676.69 $0.00 $3,620.99 $178,556.26

Transaction Detail for Plan XXXXXXTransactionType

ProcessDate Money Source Investment


Unit/SharePrice

TransactionAmount

Contributions 10/02/2009 EmployeePreTaxMatched ING FixedAccount N/A N/A $96.67



01-4447-AR-83A-010916228-0000001-0065037




Transaction Detail for Plan XXXXXX (continued)TransactionType

ProcessDate Money Source Investment


Unit/SharePrice

TransactionAmount





Total Contributions $676.69

Messages for Plan XXXXXXYOUR PERSONAL PERFORMANCE The returns shown are estimated dollar-weighted rates of return in your account, assuming evenlydistributed cashflow throughout the period. The actual timing of cash flows into and out of your account may cause your actual returns todiffer from these estimates. Past performance is no guarantee of future results.

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 INGInstitutional Plan Services, LLC. All companies are members of the ING family of companies. Securities distributed by or offered throughING Financial Advisers, LLC(member SIPC) or other broker-dealers with which it has a selling agreement.

This statement contains time sensitive financial information. Please review the statement carefully and report any discrepancies by callingone of our customer service representatives at the number shown above within 30 days of the date of this statement. Automated VoiceResponse System is available 24/7 or visit our website as shown above. Failure to report any discrepancy within 30 days will indicate thatyou are in agreement with the transactions in your account as reported on this statement.

ING EXCESSIVE TRADING POLICY Excessive trading, or Market Timing, attempts to benefit from short-term "dislocations" between theprice of a mutual fund's shares and the value of underlying securities, particularly international investments. Excessive trading within a fundforces managers to hold additional cash reserves to cover the frequent trades, which means fewer dollars to invest for all fund participants.To help protect long-term shareholders' interests, affected fund managers have implemented measures with which ING's businesses mustcomply.

ING monitors "excessive trading," currently defined as the purchase and sale twice of the same fund (including the money market fund)within a 60-day calendar period ( i.e., 2 or more round-trips of the same fund within 60 days would violate ING's policy) or 6 round-tripswithin a 12 month period. A round-trip is defined as a Buy-Sell sequence of the same fund. We do not count transfers associated withscheduled dollar cost averaging or automatic rebalancing programs and transfers involving certain de minimis amounts when determiningwhether transfer activity is excessive. When ING detects excessive trading, it may restrict or suspend Internet, phone and fax transferprivileges, however, trades can continue to be submitted via regular U.S. mail. To view ING's entire excessive trading policy refer to yourparticipant website.

AGREEMENTS TO SHARE TRADING INFORMATION WITH FUNDS As required by Rule 22c-2 under the Investment Company Act, theCompany has entered into information sharing agreements with each of the fund companies whose funds are offered through the contract.Your trading information is shared under these agreements as necessary for the fund companies to monitor fund trading and theCompany's excessive trading policy. Under these agreements, the Company is required to share information regarding your transactionsincluding but not limited to information regarding fund transfers you initiated. In addition to information about your transactions, thisinformation may include personal information, including names and social security numbers or other tax identification numbers.

As a result of this information sharing, a fund company may direct us to restrict a contract holder or participant's transactions if the funddetermines that the contract holder or participant has violated the fund's trading policies. This could include the fund directing us to rejectany allocations of purchase payments or account value to the fund.

REDEMPTION FEES SEC Rule 22c-2 requires funds to determine whether or not they should implement redemption fees to controlexcessive trading. Certain funds may deduct redemption fees as the result of withdrawals, transfers or other fund transactions a contractowner initiates. If applicable, ING may deduct the amount of any redemption fees imposed by the underlying fund(s) as a result ofwithdrawals, transfers or other fund transactions a contract owner initiates. Redemption fees, if any, are separate and distinct from anytransaction charges or other charges deducted from a contract owner's account value and are forwarded to the applicable fund. For a morecomplete description of the funds' fees and expenses, review each fund's prospectus.

01-4447-AR-83A-010916228-0000002-0065038




Messages for Plan XXXXXX (continued)

BTAKE ADVANTAGE OF CURRENT CONTRIBUTION LIMITS For 2010, you may be able to contribute a maximum of $16,500 to your403(b) or 401(k) and to your 457 retirement plan (possibly up to $19,500 for certain 403(b) participants) - and, unless your 457 plan issponsored by a nonprofit organization, if you turn 50 during 2010, you can also take advantage of the 50 plus Catch-up Provision, whichpermits you to contribute an additional $5,500 during the coming year if permitted under the terms of your plan. Employees in 457 planscan save up to $33,000 (2 x the $16,500 maximum) through the Normal Retirement Age (NRA) Catch-up Provisions. You may not useboth the NRA and the 50 plus catch-ups in the 457 plan in the same year.

YOU SHOULD CONSIDER THE INVESTMENT OBJECTIVES, RISKS, AND CHARGES, AND EXPENSES OF THE INVESTMENTOPTIONS CAREFULLY BEFORE INVESTING. PROSPECTUSES CONTAINING THIS AND OTHER INFORMATION CAN BEOBTAINED BY CONTACTING YOUR LOCAL REPRESENTATIVE. PLEASE READ THE INFORMATION CAREFULLY BEFOREINVESTING.

CGO GREEN: SAVE PAPER To receive your statement and other documents electronically, log on to your plan's website and enter yourusername and password.

To help achieve long-term retirement security, you should give careful consideration to the benefits of a well-balanced and diversifiedinvestment portfolio. Spreading your assets among different types of investments can help you achieve a favorable rate of return, whileminimizing your overall risk of losing money. This is because market or other economic conditions that cause one category of assets, orone particular security, to perform very well often cause another asset category, or another particular security, to perform poorly. If youinvest more than 20% of your retirement savings in any one company or industry, your savings may not be properly diversified. Althoughdiversification is not a guarantee against loss, it is an effective strategy to help you manage investment risk.

The Department of Labor (DOL) Internet website provides other sources of information regarding individual investing and diversification.That site can be accessed at: www.dol.gov/ebsa/investing.html

Your plan may permit each plan participant to direct the investment of some or all of the assets in his or her own account under the plan.Certain restrictions may apply to the right to direct the investment of these assets with regard to timing and the types of assets involved.Please see your Summary Plan Description or other plan related documents and materials to determine if you have the right to direct theinvestment of the assets in your own account and if so, to determine whether any restrictions apply with regard to that right. Please notethat the above message is not applicable for plans that are not subject to the ERISA guidelines, including all plans of public educationemployees.

Your plan may make available to you options (e.g. life insurance, self-directed brokerage account, and/or loans) that are not displayed onthis statement because they are not administered or made available through ING Life Insurance and Annuity Company. Please contactyour plan administrator or employer for information about these options.

01-4447-AR-83A-010916228-0000002-0065038

October 01, 2009 - December 31, 2009At Your Service:>www.ingretirementplans.comINGPO Box 990067Hartford, CT 06199-0067>TDD (Hearing Impaired): 1-800-855-2880


Page 5 of 7

Investment Performance for Plan XXXXXXSeparate Account DAverage Annual Total Returns as of: 12/31/2009

Variable annuities and funding agreements are long-term investment vehicles designed for retirement purposes which allow you to allocate contributionsamong variable investment options that have the potential to grow tax-deferred, or in the case of Roth contributions, tax free, with an option toreceive a stream of income at a later date. Early withdrawals may be subject to surrender charges, and if taken prior to age 59 1/2, a 10% IRSpenalty may apply. Taxes are due upon withdrawal of tax-deferred assets; withdrawals will also reduce the applicable death benefit and cash surrendervalue.

THE PERFORMANCE DATA QUOTED REPRESENTS PAST PERFORMANCE. PAST PERFORMANCE DOES NOT GUARANTEE FUTURERESULTS. FOR MONTH-END PERFORMANCE WHICH MAY BE LOWER OR HIGHER THAN THE PERFORMANCE DATA SHOWNPLEASE CALL 800-584-6001. INVESTMENT RETURN AND PRINCIPAL VALUE OF AN INVESTMENT WILL FLUCTUATE SOTHAT, WHEN SOLD, AN INVESTMENT MAY BE WORTH MORE OR LESS THAN THE ORIGINAL COST.

These numbers reflect total Separate Account charges of 0.00% on an annual basis. They also assume reinvestment of all dividends (ordinary income andcapital gains) and are net of management fees and other fund operating expenses.

DEPENDING UPON THE TYPE OF CONTRACT IN WHICH YOU PARTICIPATE, YOU HAVE EITHER RECEIVED DISCLOSUREBOOKLETS FOR THE SEPARATE ACCOUNT AND/OR FUND PROSPECTUSES. YOU SHOULD CONSIDER THE INVESTMENTOBJECTIVES, RISKS AND CHARGES, AND EXPENSES OF THE VARIABLE PRODUCT AND ITS UNDERLYING FUND OPTIONSCAREFULLY BEFORE INVESTING. THE DISCLOSURE BOOKLET CONTAINS THIS AND OTHER INFORMATION. ANYONE WHOWISHES TO OBTAIN A FREE COPY OF THE SEPARATE ACCOUNT DISCLOSURE BOOKLET AND/OR FUND PROSPECTUSES MAYCALL THEIR ING REPRESENTATIVE OR THE NUMBER ABOVE. PLEASE READ THE SEPARATE ACCOUNT DISCLOSUREBOOKLET AND/OR THE FUND PROSPECTUSES CAREFULLY BEFORE INVESTING.

Returns less than one year are not annualized. Fund Inception Date is the date of inception for the underlying fund, and is the date used incalculating the periodic returns. This date may also precede the portfolio's inclusion in the product.

Fund NumberInvestmentOptions 3-Mo 1-Yr 5-Yr

10-Yr/Inception

FundInception

DateStability of Principal

741 -ING FixedAccount 0.91% 3.65% 4.05% 4.87%This fund is not part of a separateaccount.Bonds

Inflation-ProtectedBond1035-PIMCO Real Return - Class A 2.08% 18.43% 4.55% 7.65% 01/29/1997

Intermediate-TermBond439 -ING PIMCO Total Return Port - Svc 0.61% 12.62% 5.48% 5.72% 05/01/2002Asset Allocation

Lifecycle747 -ING Solution2015 Portfolio- Svc 3.78% 22.32% 2.30% 04/29/2005759 -ING Solution2025 Portfolio- Svc 4.42% 25.78% 1.51% 04/29/2005762 -ING Solution2035 Portfolio- Svc 4.71% 28.35% 1.60% 04/29/2005765 -ING Solution2045 Portfolio- Svc 4.93% 29.86% 1.50% 04/29/2005768 -ING SolutionIncome Portfolio - Svc 2.78% 17.20% 2.93% 04/29/2005Balanced

Moderate Allocation1005-AmericanFunds Income Fnd R4 5.62% 24.38% 2.59% 5.91% 12/01/1973Large Cap Value

Large Blend1208-AmericanFunds Fdmntl Inv R4 6.07% 33.31% 3.94% 3.55% 08/01/19781357-ING Stock IndexPortfolio- S2 5.90% 25.79% -0.28% 1.47% 05/03/2004

Large Value617 -ING T. Rowe Price Equity Inc -Svc 5.11% 24.99% 0.50% 3.89% 01/24/1989Large Cap Growth

Large Growth572 -AmericanFunds Growth Fnd R4 5.84% 34.54% 2.86% 2.32% 12/01/1973

01-4447-AR-83A-010916228-0000003-0065039



Page 6 of 7

Investment Performance for Plan XXXXXX (continued)See PerformanceIntroduction Page for Additional Information

Separate Account DAverage Annual Total Returns as of: 12/31/2009

Fund NumberInvestmentOptions 3-Mo 1-Yr 5-Yr

10-Yr/Inception

FundInception

DateSmall/Mid/Specialty

Mid-Cap Blend457 -CRM Mid Cap Value Fund - InvestorSh 5.18% 28.41% 2.94% 9.57% 09/20/2000

Mid-Cap Growth778 -ING FMR DiversifiedMidCap Port-Svc 4.29% 39.18% 4.88% 4.99% 10/02/2000

Mid-Cap Value1008-ColumbiaMid Cap Value Fund - A 5.58% 32.25% 2.11% 6.61% 11/20/2001

Small Blend1117-LoomisSaylesSmallCapValue -Retail 3.86% 28.53% 2.44% 8.32% 05/13/1991Global / International

Foreign Large Blend573 -AmericanFunds EuroPacific R4 3.38% 39.13% 7.71% 3.62% 04/16/1984

World Stock818 -AmericanFunds Nw PrspctvFund R4 5.32% 37.45% 5.72% 3.92% 03/13/1973

The risks of investing in small company stocks may include relatively low trading volumes, a greater degree of change in earnings and greatershort-term volatility.Foreign investing involves special risks such as currency fluctuation and public disclosure, as well as economic and political risks.Some of the Funds invest in securities guaranteed by the U.S. Government as to the timely payment of principal and interest; however, shares of theFunds are not insured nor guaranteed.High yielding fixed-income securities generally are subject to greater market fluctuations and risks of loss of income and principal than areinvestments in lower yielding fixed-income securities.Sector funds may involve greater-than average risk and are often more volatile than funds holding a diversified portfolio of stocks in manyindustries. Examples include: banking, biotechnology, chemicals, energy, environmental services, natural resources, precious metals, technology,telecommunications, and utilities.

Additional Notes

The CURRENT rate for the ING Fixed Account Base + 125, Fund 741 is 3.65%, expressed as an annual effective yield, and is guaranteed not to drop below3.30% through 12/31/2010. The annual rate of interest applied to your account may be higher or lower than the current rate. Restrictions may apply totransfers of funds from the Fixed Account to other contract investment options. Please refer to your product prospectus / disclosure booklet and callyour 800 number for more information.

The Income Fund of America - Class R-4 commenced operations on May 15, 2002. The fund has identical investment objectives and policies, the sameportfolio manager, and invests in the same holdings as Class A of this fund. The performance information for The Income Fund of America - Class R-4prior to May 15, 2002 is based upon the Class A performance, adjusted by fees associated with Class R-4.The Growth Fund of America - Class R-4 commenced operations on May 15, 2002. Class R-4 has identical investment objectives and policies, the sameportfolio manager, and invests in the same holdings as Class A. The performance information above prior to May 15, 2002 is based upon the Class Aperformance adjusted by the fee differences between classes.The Loomis Sayles Small Cap Value - Retail Class commenced operations on December 31, 1996. Performance shown for periods prior to the inception dateof the Retail Class represents the performance of the Institutional Class of shares during the periods shown, adjusted to reflect the current levelsof management and 12b-1 fees payable by the respective Classes.EuroPacific Growth Fund - Class R-4 commenced operations on May 15, 2002. Class R-4 has identical investment objectives and policies, the sameportfolio manager, and invests in the same holdings as Class A. The performance information above prior to May 15, 2002 is based upon the Class Aperformance adjusted by the fee differences between classes.The New Perspective Fund - Class R-4 commenced operations on May 28, 2002. The fund has identical investment objectives and policies, the sameportfolio manager, and invests in the same holdings as Class A of this fund. The performance information for the New Perspective Fund - Class R-4prior to May 28, 2002 is based upon the Class A performance, adjusted by fees associated with Class R-4.The Investment Option is neither a mutual fund nor part of a Separate Account. The returns listed do not include the impact of contract charges.Please refer to the contract or disclosure book to determine which Fixed Interest Options are available for your specific plan. The Investment Optionis offered through ING Life and Insurance Annuity Company.

Insurance products, annuities and funding agreements issued by ING Life Insurance and Annuity Company One Orange Way Windsor, CT 06095, (ILIAC), whichis solely responsible for meeting its obligations. Plan administrative services provided by ILIAC or ING Institutional Plan Services, LLC. All

01-4447-AR-83A-010916228-0000003-0065039



Page 7 of 7

Investment Performance for Plan XXXXXX (continued)Additional Notes(continued)

companies are members of the ING family of companies. Securities are distributed by or offered through ING Financial Advisers, LLC (member SIPC) orother broker-dealers with which it has a selling agreement.

01-4447-AR-83A-010916228-0000004-0065040

5.Ded

icatedSp

onsorSu

pport&Services

An experienced, knowledgeable support teamcoupled with meaningful tools and services make iteasier for you to manage your plan and easier foremployees to participate.

Dedicated SponsorSupport & Services

3016103.C.S 14 (7/10)

DEDICATED SPONSOR SUPPORT & SERVICES

Dedicated support canhelp free up you and yourHR staff.

• Your Transition Managerleads the smooth transitionof your plan

• A Plan Manager managesthe day-to-day needs ofyour plan

• Your Client RelationsManager performs periodicplan reviews and fostersparticipant education andcommunication

• Customer ServiceAssociates handleparticipant inquiriesand answer questionsabout your plan

ING’s EASE Recordkeeping Platform Combined With Best-In-Class Service,Tools and Support Make Administering Your Retirement Plan Easier

Our knowledgeable people supported by industry-leading technology and toolsstrive to build plans that your employees understand and value, that are easierfor you to administer and feature methods to measure and improve planmetrics.

DEDICATED SUPPORT

Transition Manager

Your plan’s Transition Manager isdedicated to overseeing the successfulimplementation of your plan. Thisindividual leads a smooth transitionfrom your current service provider(s) toING. He or she will conduct animplementation discussion with you,your financial professional and yourcurrent provider within the first twoweeks after all new business paperworkis completed. ING will provide you andyour business partners with a customimplementation timeline withmilestones, and weekly conferencecalls will help keep us on track.

Plan Manager

Your plan’s Plan Manager supports theday-to-day operations of your planfollowing installation. He or she isresponsible for accurate and timelyrecordkeeping, all administrativeaspects of your plan and assisting youwith all transaction requests. The PlanManager is also responsible foroverseeing all participant transactionsinitiated by the toll-free phone line andworking with you to ensure that yourparticipant records are in balance withyour plan records.

Client Relations Manager

Your Client Relations Manager workstogether with you to implement aneducation and communicationsstrategy to motivate employees to takefull advantage of plan benefits. He orshe tracks and measures employeeresponse to ensure messages andmediums are generating impact andaction. Your CRM also conductseducational seminars and conductsperiodic plan reviews.

Customer Service Associate (CSA)

CSAs are responsible for handlingparticipant toll-free phone inquiries.These individuals free up your HRstaff by addressing plan participants’questions and concerns and by timelyprocessing transaction requests. TheCSA can provide information oninvestment performance and otherinvestment information. CSAs areavailable Monday - Friday from 8:00a.m. to 9 p.m. (ET). Every employee inour Customer Service organizationrealizes the importance of buildingquality into everything we do. In fact,it’s our mission to be recognized as aleader in delivering quality services.Employee selection, training andsupervision are geared to achieve ourgoal of 100% processing accuracy.

Periodic Plan Reviews MEANINGFUL TOOLS DESIGNEDTO HELP DELIVER SUCCESSFULOUTCOMES

Customized Plan Reviews

As a plan sponsor, your goal is tooffer a retirement program thatsatisfies the retirement needs of youand your employees. At ING, we wantto help you by providing customizedsolutions to help you reach that goalwith a periodic review of your plan.This comprehensive review includesimportant information to help youmanage your plan and keep iton track.

Your Plan Review from ING can assistyou with many of the responsibilitiesyou have as plan sponsor, such as:• Annual Due Diligence• Meeting 404(c) compliance, asapplicable to the plan

• Preparing documentation in theevent of an audit

Your Plan Review is broken downinto the following areas:• Participant Activity – Easy-to-understand plan-level analysis ofaverage participant balance,contributions and distributions,participation levels, utilization ofparticipant services and suggestedareas of improvement

• Investment Review – Fundperformance analysis anddiversification data includingassets and contributions byinvestment option, assets byinvestment style, performancereporting and fund evaluation

• Action Plan – Possible tools andcommunication materials neededto create actionable steps for thecoming year including seminarsavailable, educational materials andrecommended plan design changes(when applicable) to help maximizeretirement plan benefits

Plan Sponsor Web site with RobustOn-Demand Reporting Capabilities

ING’s Plan Sponsor Web sitedemonstrates our commitment tobringing best-in-class technology toour customers. The site combinesintuitive navigation with powerfultechnology to create a tool that helpsmake plan administration easier.

Designated sponsor representativescan enjoy “one stop” functionalitywhen logging onto ING’s Plan SponsorWeb site that includes:• 24/7 access to plan-level,participant-level and investmentinformation– Balances as of previous day– Transaction history– Year-to-date contribution amounts– Detail by participant– Investment performance

• On-Demand Reporting tool canhelp you measure plan metrics andpromote successful outcomes. Forexample, a report showing a lack ofdiversification among a populationof participants could trigger atargeted asset allocation campaignthat could help employeesunderstand the importance ofdiversification.– Choose from the list standardreports or build a custom reportfor additional detail

– “Drag and drop” functionalityoffers a user-friendly interface togenerate reports

– Generate summaries ofoperational metrics and historicaltrend analysis to help makeinformed choices regardingplan design


Sample On-Demand Reports

Visit a demo of our On-Demand Reporting tool at:www.ingretirementplans.com/reportdemo

Payroll Administration

ING allows you to choose how, andhow often you send and receiveemployee payroll information withING’s Payroll Administration tool.Using this convenient tool, you canprovide ING with participant dataelectronically and can:• Enroll eligible participants• Update participant demographicdata

• Submit and fund contributionsand/or loan repayments

• Receive automatic notifications

You can choose how you prefer toreceive data by selecting from threeconvenient options:1 FTP (File Transfer Protocol) to alocation with an e-mail notificationthat the file was sent

2 An encrypted e-mail with the fileas an attachment

3 Posted to the Plan Sponsor Web sitewith an e-mail notification that thefile has been posted

A rolling 24-month history of files willbe displayed on the Sponsor Web siteunder the Processing Center menu.

You can also choose from fourfrequency options from annually toweekly to receive your feedback file.

Automatic Plan Features

Automatic enrollment, automaticrate escalator, automatic rebalancingand automatic eligibility monitoringcan help take the “admin” out ofadministering your plan. You canchoose to include any or all of theseconvenient auto features in yourplan’s design.

Online Beneficiary Tracking Service

ING can store and update beneficiaryinformation for your plan participants,and on an ongoing basis provide youwith a simple summary for yourrecords. This feature eliminates theneed for you to collect paperbeneficiary forms.

Automated Eligibility Monitoring*

ING assumes responsibility formonitoring employee eligibility andthen notifying employees of theirability to participate in the plan—which results in less administration forthe plan sponsor. Newly eligibleemployees receive a letter andbrochure mailed to their homesexplaining the benefits of contributingto the plan and how to enroll.

Online Targeted and CustomWeb Messaging

We believe that people are typicallymore likely to take action when amessage is targeted for their uniquesituation. That is why our ParticipantWeb site features the ability to createand post customized messages,reminders and alerts on-demand to aparticipant's bulletin board.

ING Benchmark Wizard

An industry first, the ING BenchmarkWizard provides you with detailedretirement plan statistics and gives youan inside look into what retirementbenefits similar companies in yourindustry are offering their employees.The innovative technology of the INGBenchmark Wizard allows yourrepresentative to enter your plan dataand retrieve results from an expansivedatabase, instantly providing you withdetailed information on your plan –and how it stacks up against the plansof your peers. The ING BenchmarkWizard filters retirement planinformation based on:• Industry• Plan Type• Tax Code• Number of Employees• Number of Assets

Plan Sponsor Newsletter

ING’s periodic plan sponsor newsletterhelps keep you informed on relevantissues such as legislative updates,administrative changes and newproducts and services.

Payroll Administration

Custom Web Messaging

ING Benchmark Wizard

ING Institute forRetirement Research (IIRR)

www.ingretirementresearch.comThe IIRR is a source for information,tools and commentary to helpemployers make better use of theirretirement resources.

* Available for full service plans with $3M in assets.

Recordkeeping and Plan Services

Backed by our experienced serviceteam, our multiple service platformswill deliver everything you’ll need tokeep your plan running smoothly.Recognizing that you have otherresponsibilities, our services aredesigned to support you in your role.Our recordkeeping services includeprocessing enrollments, ongoingmonitoring of participant data andcontribution limits, and distributionprocessing. Other services include:• Daily valuation and reconciliation• Account rebalancing• Allocation of plan contributionsand loan repayments

• Reallocation of forfeitures• Hourly vesting calculations• Ability to work with any type ofpayroll or census feed

Thorough Testing

Accurate and thorough testing ensuresyour plan remains in compliance. Weprovide signature-ready Form 5500s,and conduct the Actual DeferralPercentage (ADP) and ActualContribution Percentage (ACP) testson a semi-annual basis. Top-heavy and415 (annual additions) testing isconducted if this is the only planyou maintain.• ADP/ACP testing• Top heavy testing• 415 and 402(g)• 410(b) and 401(a)(4)• Signature-ready 5500 and allapplicable schedules

• Plan audit assistance


3016103.C.S 15 (7/10)

6.Leadingwith

Technology

Data-mining tools designed to promote successfuloutcomes, improve plan metrics and reduce youradministrative workload.

Leading withTechnology

3016103.C.S 16 (7/10)

Plan Sponsor Web Site

It’s powerful, easy-to-use and givesdesignated sponsor representativestotal access to information and toolsnecessary to effectively manage andmonitor their retirement plan. ING'sPlan Sponsor Web site is an onlineentry-point to an array of reportingand management tools including:• 24/7 access to plan-level,participant-level and investmentinformation

• Balances as of previous day• Transaction history• Year-to-date contribution amounts• Detail by participant• Investment performance• On-Demand Reporting Tool

On-Demand Reporting Tool

This robust data-mining tool providespowerful access to a wide range ofplan data to help measure andimprove plan metrics and identifyeducation opportunities.• Choose from the list standardreports or build a custom report foradditional detail

• “Drag and drop” functionality offersa user-friendly interface to generatereports

• Generate summaries of operationalmetrics and historical trend analysisto help make informed choicesregarding plan design

LEADING WITH TECHNOLOGY

Superior technology and tools supported by experienced andknowledgeable professionals.

Throughout the pages of this proposal, it’s clear that ING is committed todeveloping and delivering the type of best-in-class technology that supports thesuccess of your plan and its participants. Our leading technology, combinedwith our personalized service, create retirement plans that are easier toadminister and easier for employees to benefit from all they have to offer.

Partcipant Web Site

Participants have complete controlover their plan account and access topersonalized education through ING’sParticipant Web site. Features include:• Targeted and customized messageboard provide the ability to postcustom messages and alerts toencourage participants to takeaction

• Personalized Market Watch Tool thatcan be customized to includepreferred ticker symbols

• Financial Resource Center thatfeatures personalized onlinefinancial education

• Online beneficiary maintenance• Robust planning calculators• Manage contributions and trackinvestments

• Model and request loans

Visit a demo of our Plan Sponsor Web site at:www.ingretirementplans.com/sponsorwebdemo

Visit a demo of our On-Demand Reporting tool at:www.ingretirementplans.com/reportdemo

Visit a demo of our Participant Web site at:www.ingretirementplans.com/pwebdemo

Plan Sponsor Web Site

On-Demand Reporting Tool

Partcipant Web Site

LEADING WITH TECHNOLOGY

ING Innovation Strives to Improve Retirement Readiness

Through our commitment to and investment in thoughtful research andpurposeful innovation, ING continually seeks to improve the retirement readinessof Americans. These three behavior-changing tools were developed by ING toeducate and motivate individuals to take action and save more for retirement.

INGCompareMe.comBy leveraging the power of peercomparison, this tool makes it possiblefor your employees to discover how theycompare to others in their peer group onfinancial matters, and ways to increasetheir retirement savings.

Visit a demo of INGCompareMe.com at:www.ingcompareme.com

My Retirement OutlookThis unique retirement calculator helpsemployees better prepare to close theretirement income gap by combiningretirement and paycheck analysis withan instant gap statement thathighlights the gap between whatparticipants are currently saving andwhat may be needed to meet theirretirement objectives.

Visit a demo of My Retirement Outlook at:www.ingretirementplans.com/mrodemoCHC

INGYourNumber.comResearch has shown that 54% ofworkers* have never calculated howmuch money they will need to livecomfortably in retirement. Thispowerful tool helps people find theirpersonal “number” of the amount ofmoney they will need to retire the waythey want. Once they know theirNumber, they can work towardachieving it.

To calculate your number, visit www.ingyournumber.com

3016103.C.S 17 (7/10)

*2010 Retirement Confidence Survey, EBRI 2010

7.Program

Highlig

hts

Program Highlights

3016103.C.S 18 (7/10)

8.Investm

entPerfo

rman

ce

Investment Performance

3016103.C.S 19 (7/10)

9.Appen

dix

Appendix

3016103.C.S 20 (7/10)

Supplement to MAP Select Participant and Plan Sponsor Information Booklets

MAPSelectRevSupp-09 (10/09)

1

ING MAP SELECT

Supplement dated October, 2009 This supplement updates the contract information booklet and provides you (the employee/participant and/or the plan sponsor, as applicable) with important information regarding fund revenue sharing and expenses, sales compensation, third party administrator compensation, the availability of other products from ING Life Insurance and Annuity Company (the Company) and other important information. I. FUND REVENUE SHARING AND EXPENSE DISCLOSURE Fees Deducted by the Funds The investment advisory fees, 12b-1 fees and other expenses including service fees (if applicable) that may be charged annually by each fund are disclosed in a Fund Fees and Expenses Table available from your sales representative. The fund fee and expense information listed in the Fund Fees and Expenses Table was provided by the funds. See “Fund Fees and Expenses” below and the fund prospectuses for further information. Fund fees are one factor that impacts the value of a fund share. To learn about additional factors, refer to the fund prospectuses. The Company or its affiliates may receive compensation from each of the funds or the funds’ affiliates based on an annual percentage of the average net assets held in that fund by the Company. The percentage paid may vary from one fund company to another. For certain funds, some of this compensation may be paid out of 12b-1 fees or service fees that are deducted from fund assets. Any such fees deducted from fund assets are disclosed in the fund prospectuses. The Company or its affiliates may also receive additional compensation from certain funds for administrative, recordkeeping or other services provided by the Company or its affiliates to the funds or the funds’ affiliates. These additional payments may also be used by the Company or its affiliates to finance distribution. These additional payments are made by the funds or the funds’ affiliates to the Company or its affiliates and do not increase, directly or indirectly, the fund fees and expenses. In the case of fund companies affiliated with the Company, where an affiliated investment adviser employs subadvisers to manage the funds, no direct payments are made to the Company or the affiliated investment adviser by the subadvisers. Subadvisers may provide reimbursement for employees of the Company or its affiliates to attend business meetings or training conferences. Investment management fees are apportioned between the affiliated investment adviser and subadviser. This apportionment varies by subadviser, resulting in varying amounts of revenue retained by the affiliated investment adviser. This apportionment of the investment advisory fee does not increase, directly or indirectly, fund fees and expenses. See “Fund Fees and Expenses” below for additional information. How Fees are Deducted. Fund fees are not deducted from account values. Instead, fund fees are deducted from the value of the fund shares on a daily basis. If the fund shares are offered under a group annuity contract or group funding agreement, as applicable, this will in turn affect the value of subaccounts that purchase the fund shares. Fund Share Classes. A single mutual fund usually offers more than one “class” of shares to investors. The key distinctions between these share classes are the charges and ongoing fees borne by the fund and absorbed by investors. These fees may include 12b-1 fees as well as administrative and “Sub-TA” fees (sometimes called service fees). The least expensive classes of mutual fund shares are often called “Initial Class” or “Class I” and generally only charge management fees and limited fees for other expenses related to the fund. These classes of shares usually generate the least amount of revenue for the Company, although they may pay service fees. Various share classes may charge 12b-1 fees up to 0.75%. These classes are often called Class A, Service Class, Adviser Class, R Class or S Class shares. They may also have other names.



2

The mutual fund component of this product may make more than one menu of funds available for the plan sponsor to select from. Generally, these menus differ from one another according to ranges of fund fee expense levels, administrative fund fees, and by share class. Plan sponsors should know that the expense levels associated with a fund menu may affect billed expenses, daily asset charges and other features of the product. This is because other product charges are related to the amount of fund revenue that the Company receives. Plan sponsors should discuss with their sales professional how fund revenues may affect services provided as well as other product fees and charges, as mentioned above. Fund Fee Adjustment. As described above, the Company earns varying levels of revenue from the funds available under the product. The Company assesses an additional fee (called an administrative fund fee) against certain funds in order to limit the effect of fund revenue differentials on other product pricing features. The administrative fund fee may be positive or negative (a negative fee is applied as a credit against the product's daily asset charge (if any). Fund Fees and Expenses As shown in the Fund Fees and Expenses Table, each fund deducts management fees from the amounts allocated to the fund. In addition, each fund deducts other expenses which may include service fees that may be used to compensate service providers, including the Company and its affiliates, for administrative and contract owner or participant services provided on behalf of the fund. Furthermore, certain funds deduct a distribution or 12b-1 fee, which is used to finance any activity that is primarily intended to result in the sale of fund shares. For a more complete description of the funds' fees and expenses, review each fund's prospectus. The Company or its U.S. affiliates [generally] receive substantial revenue from each of the funds or the funds’ affiliates, although the amount and types of revenue vary with respect to each of the funds offered through the contract. This revenue is one of several factors we consider when determining contract fees and charges and whether to offer a fund through our contracts. Fund revenue is important to the Company’s profitability, and it is generally more profitable for us to offer affiliated funds than to offer unaffiliated funds. In terms of dollar amounts received, the greatest amount of revenue generally comes from assets allocated to funds managed by Directed Services LLC or other Company affiliates, which funds may or may not also be subadvised by a Company affiliate. Assets allocated to funds managed by a Company affiliate but subadvised by unaffiliated third parties typically generate the next greatest amount of revenue. Finally, assets allocated to unaffiliated funds typically generate the least amount of revenue. The Company expects to make a profit from this revenue to the extent it exceeds the Company’s expenses, including the payment of sales compensation to our distributors. Types of Revenue Received from Affiliated Funds Affiliated funds are (a) funds managed by Directed Services LLC or other Company affiliates, which may or may not also be subadvised by another Company affiliate; and (b) funds managed by a Company affiliate but which are subadvised by unaffiliated third parties. Revenues received by the Company from affiliated funds may include: • A share of the management fee deducted from fund assets and included within the “Management

Fees” column of the Fund Fees and Expenses Table; • Service fees that are deducted from fund assets and included within the “Other Expenses” column of

the Fund Fees and Expenses Table; • For certain share classes, the Company or its affiliates may also receive compensation paid out of

12b-1 fees that are deducted from fund assets and disclosed in the “12b-1 Fees” column of the Fund Fees and Expenses Table; and



3

• Other revenues that may be based either on an annual percentage of average net assets held in the fund by the Company or a percentage of the fund’s management fees shown in the Fund Fees and Expenses Table.

These revenues may be received as cash payments or according to a variety of financial accounting techniques that are used to allocate revenue and profits across the organization. In the case of affiliated funds subadvised by unaffiliated third parties, any sharing of the management fee between the Company and the affiliated investment adviser is based on the amount of such fee remaining after the subadvisory fee has been paid to the unaffiliated subadviser. Because subadvisory fees vary by subadviser, varying amounts of revenue are retained by the affiliated investment adviser and ultimately shared with the Company. Types of Revenue Received from Unaffiliated Funds Revenues received from each of the unaffiliated funds or their affiliates are based on an annual percentage of the average net assets held in that fund by the Company. Some unaffiliated funds or their affiliates pay us more than others and some of the amounts we receive may be significant. Revenues received by the Company from unaffiliated funds include: • For certain funds, compensation paid from 12b-1 fees or service fees that are deducted from fund

assets. Any such fees deducted from fund assets are disclosed in the Fund Fees and Expenses Table; and

• Additional payments for administrative, recordkeeping or other services which we provide to the funds

or their affiliates, such as processing purchase and redemption requests, and mailing fund prospectuses, periodic reports and proxy materials. These additional payments are not disclosed in the Fund Fees and Expenses Table and do not increase directly or indirectly the fees and expenses shown in the Fund Fees and Expenses Table. These additional payments may be used by us to finance distribution of the contract.

These revenues are received as cash payments. The following table shows the top twenty-five unaffiliated fund families ranked according to the total amount they paid to the Company or its affiliates in 2008, in connection with unregistered variable separate account contracts issued by the Company:

American FundsSM Fidelity Investments® 1 Pioneer Investment Management Lord Abbett Funds Franklin® Templeton® Investments 2 Baron Funds® OppenheimerFunds, Inc. Columbia Funds T. Rowe Price Funds 3 Allianz Funds Invesco AimSM 4 American Century Investments AllianceBernstein L.P.

Pax World Funds Ariel Investments CRM Funds 5 BlackRock, Inc. Lazard Asset Management LLC Davis Funds RiverSource Investments, LLC MFS Investment Management® 6 Eaton Vance Distributors, Inc. Morgan Stanley Investment Management, Inc. 7 Munder Capital Management® Evergreen InvestmentsSM 8

________________________________ 1 Fidelity and Fidelity Investments are registered trademarks of FMR Corp. 2 Franklin and Templeton are registered trademarks of Franklin Resources, Inc. or its subsidiaries. 3 T. Rowe Price, Invest With Confidence, the Big Horn Sheep and the logo they compose are trademarks or

registered trademarks of T. Rowe Price Group, Inc. in the U.S. and other countries.



4

4 Invesco AimSM is a service mark of Invesco Aim Management Group, Inc. Invesco Aim Advisors, Inc. is one of the

investment advisors for the products and services represented by Invesco Aim; it provides investment advisory services to individual and institutional clients and does not sell securities.

5 "CRM Funds" are distributed by "Professional Funds Distributors, Inc." 6 MFS Investment Management® is a registered trademark of Massachusetts Financial Services Company. 7 Morgan Stanley Investment Management Inc. does business in certain instances using the name Van Kampen. 8 Evergreen InvestmentsSM is a service mark of Evergreen Investments Management Company, LLC. Copyright,

2008, Evergreen Investment Management Company, LLC. If the revenues received from affiliated funds were included in the table above, payments from Directed Services LLC and other Company affiliates would be first on the list. Please note certain management personnel and other employees of the Company or its affiliates may receive a portion of their total employment compensation based on the amount of net assets allocated to affiliated funds. In addition to the types of revenue received from affiliated and unaffiliated funds described above, affiliated and unaffiliated funds and their investment advisers, subadvisers or affiliates may participate at their own expense in Company sales conferences or educational and training meetings. In relation to such participation, a fund's investment adviser, subadviser or affiliate may help offset the cost of the meetings or sponsor events associated with the meetings. In exchange for these expense offset or sponsorship arrangements, the investment adviser, subadviser or affiliate may receive certain benefits and access opportunities to Company sales representatives and wholesalers rather than monetary benefits. These benefits and opportunities include, but are not limited to co-branded marketing materials; targeted marketing sales opportunities; training opportunities at meetings; training modules for sales personnel; and opportunity to host due diligence meetings for representatives and wholesalers. Certain funds may be structured as “fund of funds” (including the ING Index Solution portfolios, ING Retirement portfolios and ING Solution portfolios) or “Master Feeder” funds (including the Eaton Vance Large-Cap Value Fund and ING Fidelity VIP Portfolios) which may be available under the contract for your plan. These funds may have higher fees and expenses than a fund that invests directly in debt and equity securities, because they also incur the fees and expenses of the underlying funds in which they invest. Some of these funds are affiliated funds, and the underlying funds in which they invest may be affiliated as well. The fund prospectuses and the mutual fund fact sheets disclose the aggregate annual operating expenses of each portfolio and its corresponding underlying fund or funds. II. SALES COMPENSATION DISCLOSURE Contract Distribution The Company's subsidiary, ING Financial Advisers, LLC, serves as the distributor for the contracts. ING Financial Advisers, LLC, a Delaware limited liability company, is registered as a broker-dealer with the SEC. ING Financial Advisers, LLC is also a member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). ING Financial Advisers, LLC's principal office is located at One Orange Way, Windsor, Connecticut 06095-4774. The contracts are offered to the public by sales professionals who are registered representatives of ING Financial Advisers, LLC, registered representatives of other broker-dealers which have entered into a selling arrangement with ING Financial Advisers, LLC, or not registered with any broker-dealer. We refer to ING Financial Advisers, LLC and the other broker-dealers selling the contracts as “distributors.” All sales professionals selling the contracts must be appropriately licensed as insurance agents for the Company.



5

The following is a list of broker-dealers that are affiliated with the Company: Bancnorth Investment Group, Inc. Directed Services LLC Financial Network Investment Corporation Guaranty Brokerage Services, Inc. ING America Equities, Inc. ING DIRECT Funds Limited ING Financial Advisers, LLC ING Financial Markets LLC

ING Financial Partners, Inc. ING Funds Distributor, LLC ING Investment Advisors, LLC ING Investment Management Services LLC Multi-Financial Securities Corporation PrimeVest Financial Services, Inc. ShareBuilder Securities Corporation Systematized Benefits Administrators, Inc.

Registered representatives of distributors who solicit sales of the contracts typically receive a portion of the compensation paid to the distributor in the form of commissions or other compensation, depending upon the agreement between the distributor and the registered representative. This compensation, as well as other incentives or payments, is not paid directly by plan sponsors or participants. We intend to recoup this compensation and other sales expenses paid to distributors through fees and charges imposed under the contracts. Compensation Arrangements Commission Payments. Sales professionals provide numerous services, including services to plan sponsors and participants. These include installing and servicing contracts, providing product explanations, and periodically reviewing participants' retirement needs as well as the investment options available under the contract. Compensation to sales professionals is provided through sales commissions. Commissions paid on transferred assets and recurring contributions made during the first year of the contract or, if applicable, participant account range from 0% to 2.0%. After the first year of the contract or, if applicable, participant account, renewal commissions ranging from 0% to 2.0% may be paid on recurring contributions and extraordinary contributions. In addition, the Company may pay an asset based commission ranging up to 1.0% per year. Sales professionals who are registered with a distributor may receive all or a portion of compensation paid to their distributor, depending upon the firm's practices. The amount of commissions and annual payments paid to your sales professional is disclosed in the written materials we provide at the point of sale. Your sales professional may select the level of compensation he or she receives in connection with the sale of the contract. The factors the sales professional may consider in selecting the level of compensation include the complexity of the case, the level of sales and ongoing service support to be provided by the sales professional and the costs incurred by the sales professional in providing that support. The level of commission paid on a particular contract affects the level of charges under the contract, including the daily asset charge and the applicability of an early withdrawal charge schedule. The level of commission paid on a particular contract may also affect the rate credited to the Fixed Account and/or the Guaranteed Accumulation Account, if applicable. Because the sales professional may select the level of compensation he or she receives in connection with the sale of the contract, he or she may have a financial incentive to recommend this contract over other contracts. The plan sponsor should discuss with the sales professional the level of compensation he or she will choose in connection with the sale of this contract and how that compensation may compare with compensation available under other products or contracts the sales professional feels may be suitable for you. Plan sponsors interested in obtaining more information about the compensation options available to their sales professional and how they impact the charges and terms of your contract, including the daily asset charge, the rate credited to the Fixed Account, and the selection of share classes to be included in your contract, should consult with their sales professional. Other Compensation Arrangements. We may also enter into special compensation arrangements with certain distributors based on those firms' aggregate or anticipated sales of the contracts, or other criteria. These special compensation arrangements will not be offered to all distributors, and the terms of such



6

arrangements may differ among distributors based on various factors. These special compensation arrangements may also be limited only to ING Financial Advisers, LLC and other distributors affiliated with the Company. Any such compensation payable to a distributor will not result in any additional direct charge to you by us. To the extent permitted by SEC and FINRA rules and other applicable laws and regulations, we may also pay or allow other promotional incentives or payments in the form of cash payments or other compensation to sales professionals and distributors, which may require the sales professional or distributor to attain a certain threshold of sales of Company products. These other promotional incentives or payments may not be offered to all distributors, and may be limited only to ING Financial Advisers, LLC and other distributors affiliated with the Company. Some sales personnel may receive various types of non-cash compensation as special sales incentives, including trips and we may also pay for some sales personnel to attend educational and/or business seminars. Any such compensation will be paid in accordance with SEC and FINRA rules. Management personnel of the Company, and of its affiliated broker-dealers, may receive additional compensation if the overall amount of investments in funds advised by the Company or its affiliates meets certain target levels or increases over time. Compensation for certain management personnel, including sales management personnel, may be enhanced if management personnel meet or exceed goals for sales of the contracts, or if the overall amount of investments in the contracts and other products issued or advised by the Company or its affiliates increases over time. Certain sales management personnel may also receive compensation that is a specific percentage of the commissions paid to distributors or of purchase payments received under the contracts, or which may be a flat dollar amount that varies based upon other factors, including management’s ability to meet or exceed service requirements, sell new contracts or retain existing contracts, or sell additional service features such as a common remitting program. In addition to direct cash compensation for sales of contracts described above, sales professionals and distributors may also be paid additional compensation or reimbursement of expenses for their efforts in selling contracts to plan sponsors and other customers. These amounts may include: • Marketing/distribution allowances that may be based on the percentages of purchase payments

received, the aggregate commissions paid and/or the aggregate assets held in relation to certain types of designated insurance products issued by the Company and/or its affiliates during the year;

• Education and training allowances to facilitate our attendance at certain educational and training

meetings to provide information and training about our products, including holding training programs from time to time at our own expense;

• Sponsorship payments or reimbursements for distributors to use in sales contests and/or meetings for

their sales professionals who sell our products. We do not hold contests based solely on sales of this product;

• Certain overrides and other benefits that may include cash compensation based on the amount of

earned commissions, representative recruiting or other activities that promote the sale of contracts; • Loans or advances of commissions in anticipation of future receipt of purchase payments (a form of

lending to registered representatives). These loans may have advantageous terms, such as reduction or elimination of the interest charged on the loan and/or forgiveness of the principal amount of the loan, which may be conditioned on contract sales.

• Additional cash or noncash compensation and reimbursements permissible under existing law. This

may include, but is not limited to, cash incentives, merchandise, trips, occasional entertainment, meals and tickets to sporting events, client appreciation events, business and educational enhancement items, payment for travel expenses (including meals and lodging) to pre-approved training and education seminars, and payment for advertising and sales campaigns.



7

We pay dealer concessions, wholesaling fees, overrides, bonuses, other allowances and benefits and the costs of all other incentives or training programs from our resources, which include the fees and charges imposed under the contract. The following is a list of the top twenty-five selling firms that, during 2008, received the most compensation, in the aggregate, from us in connection with the sale of packaged programs and registered and unregistered variable separate account contracts issued by the Company, ranked by total dollars received. Fidelity Insurance Agency, Inc. ING Financial Partners, Inc. LPL Financial Corporation NFP Securities, Inc. Park Avenue Securities, LLC Financial Network Investment Corporation SagePoint Financial, Inc. Lincoln Financial Securities Corporation NRP Financial, Inc. Lincoln Financial Advisors Corporation Symetra Investment Services, Inc. Morgan Keegan and Company, Inc. Northwestern Mutual Investment Services, LLC

Walnut Street Securities, Inc.® Morgan Stanley & Co., Incorporated Mutual Service Corporation Huckin Financial Group, Inc. Tower Square Securities, Inc. Financial Telesis Inc./JHW Financial & Insurance Services Multi-Financial Securities Corporation American Portfolios Financial Services, Inc. National Planning Corporation Royal Alliance Associates, Inc. Securities America, Inc. M Holdings Securities, Inc.

If the amounts paid to ING Financial Advisers, LLC, were included, ING Financial Advisers, LLC would be first on the list. This is a general discussion of the types and levels of compensation paid by us for the sale of our unregistered variable separate account contracts. It is important for you to know that the payment of volume or sales-based compensation to a distributor or sales professional, along with the ability of the sales professional to select from various compensation options, may provide that sales professional a financial incentive to promote our contracts over those of another company, and may also provide a financial incentive to promote one of our contracts over another. The names of the distributor and/or the sales professional responsible for the contract are stated in separate disclosure materials. Third Party Administrator Compensation Arrangements. Some retirement plans utilize the services of a third party administrator (TPA). If the plan sponsor has retained the services of a TPA, your TPA may participate in our Alliance and/or Partnership TPA Service Reimbursement Programs. Payments under these programs are intended to reward TPAs who work effectively with the Company's systems and processes to facilitate the efficient delivery of Company products and services. The local delivery by independent TPAs of plan and compliance services helps fulfill the service needs of many of our customers. At the same time, the Company's local TPA relationships also help us improve the efficiency and effectiveness of our product offerings and marketing strategy. TPAs assist us in educating brokers about our products and capabilities. In addition, the Company hosts TPA conferences each year to provide forums for the exchange of ideas on best practices relating to the servicing and administration of retirement plans. The conferences also serve as platforms for discussing the Company's product initiatives and how well those initiatives are meeting market needs. Attendees may be reimbursed for all or a portion of their attendance costs and may receive meals and entertainment at such conferences. Eligibility for payments and the amount of payment is subject to the Company's guidelines. Qualification criteria include demonstrated ability to effectively interface with Company systems and processes, retention and growth in assets and the number of plans serviced by the Company and the TPA, and participation in Company education/training and consulting programs. Payments under the Alliance Program range from 0.02% to 0.96% of first year contributions (including transferred assets). Payments under the Partnership Program are up to 0.05% annually on the average of assets maintained in the plan.



8

The Company does not adjust your particular contract fees based on whether your TPA participates in either or both programs. Our contract fees generally reflect the overall costs we incur in providing the product and services to you, including the costs of payments to third parties. Other Third Party Compensation Arrangements • The Company may seek to promote itself and the contracts by sponsoring or contributing to events

sponsored by various associations, professional organizations and labor organizations. • The Company may make payments to associations and organizations, including labor organizations,

which endorse or otherwise recommend the contracts to their membership. If an endorsement is a factor in your contract purchasing decision, more information on the payment arrangement, if any, is available upon your request.

• At the direction of the contract plan sponsor, we may make payments to the contract plan sponsor, its representatives or third party service providers intended to defray or cover the costs of plan or program-related administration.

III. PRODUCT SUITE DISCLOSURE We and our affiliates offer various other products with different features and terms than these contracts that may offer some or all of the same funds. These products differ according to benefits, fees and charges. Plan sponsors who are interested in learning more about these other products may contact their sales professional. IV. OTHER IMPORTANT INFORMATION REGARDING OUR EXCESSIVE TRADING POLICY The contract is not designed to serve as a vehicle for frequent transfers. Frequent transfer activity can disrupt management of a fund and raise its expenses through: • Increased trading and transaction cost; • Forced and unplanned portfolio turnover; • Lost opportunity costs; and • Large asset swings that decrease the fund’s ability to provide maximum investment return to all

contract owners and participants. This in turn can have an adverse effect on fund performance. Accordingly, individuals or organizations that use market-timing investment strategies or make frequent transfers should not purchase or participate in the contract. Excessive Trading Policy. The Company and its affiliates that provide multi-fund variable insurance and retirement products have adopted a common Excessive Trading Policy to respond to the demands of the various fund families that make their funds available through our products to restrict excessive fund trading activity and to ensure compliance with Rule 22c-2 of the Investment Company Act of 1940 (1940 Act). We actively monitor fund transfer and reallocation activity within our variable insurance products and retirement products to identify violations of our Excessive Trading Policy. Our Excessive Trading Policy is violated if fund transfer and reallocation activity: • Meets or exceeds our current definition of Excessive Trading, as defined below; or • Is determined, in our sole discretion, to be disruptive or not in the best interests of other owners of our

variable insurance and retirement products, or participants in such products.



9

We currently define “Excessive Trading” as: • More than one purchase and sale of the same fund (including money market funds) within a 60

calendar day period (hereinafter, a purchase and sale of the same fund is referred to as a “round-trip”). This means two or more round-trips involving the same fund within a 60 calendar day period would meet our definition of Excessive Trading; or

• Six round-trips involving the same fund within a rolling twelve month period. The following transactions are excluded when determining whether trading activity is excessive: • Purchases or sales of shares related to non-fund transfers (for example, new purchase payments,

withdrawals and loans); • Transfers associated with scheduled dollar cost averaging, scheduled rebalancing, or scheduled

asset allocation programs; • Purchases and sales of fund shares in the amount of $5,000 or less; • Purchases and sales of funds that affirmatively permit short-term trading in their fund shares, and

movement between such funds and a money market fund; and • Transactions initiated by us, another member of the ING family of companies, or a fund. If we determine that an individual or entity has made a purchase of a fund within 60 days of a prior round-trip involving the same fund, we will send them a letter (once per year) warning that another sale of that same fund within 60 days of the beginning of the prior round-trip will be deemed to be Excessive Trading and result in a six month suspension of their ability to initiate fund transfers or reallocations through the Internet, facsimile, Voice Response Unit (VRU), telephone calls to the ING service center or other electronic trading medium that we may make available from time to time (“Electronic Trading Privileges”). Likewise, if we determine that an individual or entity has made five round-trips involving the same fund within a rolling twelve month period, we will send them a letter warning that another purchase and sale of that same fund within twelve months of the initial purchase in the first round-trip will be deemed to be Excessive Trading and result in a suspension of their Electronic Trading Privileges. According to the needs of the various business units, a copy of any warning letters may also be sent, as applicable, to the person(s) or entity authorized to initiate fund transfers or reallocations, the agent/registered representative, or the investment adviser for that individual or entity. A copy of the warning letters and details of the individual’s or entity’s trading activity may also be sent to the fund whose shares were involved in the trading activity. If we determine that an individual or entity has violated our Excessive Trading Policy, we will send them a letter stating that their Electronic Trading Privileges have been suspended for a period of six months. Consequently, all fund transfers or reallocations, not just those that involve the fund whose shares were involved in the activity that violated our Excessive Trading Policy, will then have to be initiated by providing written instructions to us via regular U.S. mail. Suspension of Electronic Trading Privileges may also extend to products other than the product through which the Excessive Trading activity occurred. During the six month suspension period, electronic “inquiry only” privileges will be permitted where and when possible. A copy of the letter restricting future transfer and reallocation activity to regular U.S. mail and details of the individual’s or entity’s trading activity may also be sent, as applicable, to the person(s) or entity authorized to initiate fund transfers or reallocations, the agent/registered representative or investment adviser for that individual or entity, and the fund whose shares were involved in the activity that violated our Excessive Trading Policy. Following the six month suspension period during which no additional violations of our Excessive Trading Policy are identified, Electronic Trading Privileges may again be restored. We will continue to monitor the fund transfer and reallocation activity, and any future violations of our Excessive Trading Policy will result in an indefinite suspension of Electronic Trading Privileges. A violation of our Excessive Trading Policy during the six month suspension period will also result in an indefinite suspension of Electronic Trading Privileges.



10

We reserve the right to suspend Electronic Trading Privileges with respect to any individual or entity, with or without prior notice, if we determine, in our sole discretion, that the individual’s or entity’s trading activity is disruptive or not in the best interests of other owners of our variable insurance and retirement products, or participants in such products, regardless of whether the individual’s or entity’s trading activity falls within the definition of Excessive Trading set forth above. Our failure to send or an individual’s or entity’s failure to receive any warning letter or other notice contemplated under our Excessive Trading Policy will not prevent us from suspending that individual’s or entity’s Electronic Trading Privileges or taking any other action provided for in our Excessive Trading Policy. The Company does not allow exceptions to our Excessive Trading Policy. We reserve the right to modify our Excessive Trading Policy, or the policy as it relates to a particular fund, at any time without prior notice, depending on, among other factors, the needs of the underlying fund(s), the best interests of contract owners, participants, and fund investors, and/or state or federal regulatory requirements. If we modify our policy, it will be applied uniformly to all contract owners and participants or, as applicable, to all contract owners and participants investing in the underlying fund. Our Excessive Trading Policy may not be completely successful in preventing market-timing or excessive trading activity. If it is not completely successful, fund performance and management may be adversely affected, as noted above. Limits Imposed by the Underlying Funds. Each underlying fund available through the variable insurance and retirement products offered by us and/or the other members of the ING family of companies, either by prospectus or stated policy, has adopted or may adopt its own excessive/frequent trading policy, and orders for the purchase of fund shares are subject to acceptance or rejection by the underlying fund. We reserve the right, without prior notice, to implement fund purchase restrictions and/or limitations on an individual or entity that the fund has identified as violating its excessive/frequent trading policy and to reject any allocation or transfer request to a subaccount if the corresponding fund will not accept the allocation or transfer for any reason. All such restrictions and/or limitations (which may include, but are not limited to, suspension of Electronic Trading Privileges and/or blocking of future purchases of a fund or all funds within a fund family) will be done in accordance with the directions we receive from the fund. Agreements to Share Information with Fund Companies. As required by Rule 22c-2 under the 1940 Act, we have entered into information sharing agreements with each of the fund companies whose funds are offered through the contract. Contract owner and participant trading information is shared under these agreements as necessary for the fund companies to monitor fund trading and our implementation of our Excessive Trading Policy. Under these agreements, the Company is required to share information regarding contract owner and participant transactions, including but not limited to information regarding fund transfers initiated by you. In addition to information about contract owner and participant transactions, this information may include personal contract owner and participant information, including names and social security numbers or other tax identification numbers. As a result of this information sharing, a fund company may direct us to restrict a contract owner or participant’s transactions if the fund determines that the contract owner or participant has violated the fund’s excessive/frequent trading policy. This could include the fund directing us to reject any allocations of purchase payments or account value to the fund or all funds within the fund family.



11

Redemption Fees. Also as part of complying with Rule 22c-2 under the 1940 Act, certain fund companies may deduct redemption fees as the result of withdrawals, transfers or other fund transactions that a participant or the plan sponsor initiates. If applicable, the Company may deduct the amount of any redemption fees imposed by the fund(s). These fees are separate and distinct from any transaction charges or other charges deducted from a participant’s account value. For a more complete description of the funds’ fees and expenses, review the fund prospectuses.

You should consider the investment objectives, risks, charges and expenses of the variable product and its underlying fund options carefully before investing. The fund prospectuses and information booklets contain this and other information, which can be obtained by contacting your local representative. Please read the information carefully before investing.

IRS Circular 230 Disclosure: These materials are not intended to be used to avoid tax penalties, and were prepared to support the promotion or marketing of the matter addressed in this document. The taxpayer should seek advice from an independent tax adviser.

To request information about this contract or if you have questions: Plan Sponsors: Please call Plan Sponsor Services toll free at 1-888-410-9482. Participants: Please contact us at the toll free phone number found in your enrollment material.

Complaints? Please contact us at: ING Life Insurance and Annuity Company, Contact Center – B2S P.O. Box 99065 Hartford, CT 06199-0065.

By telephone, participants should contact us at the toll free phone number found in your enrollment material; plan sponsors may use the toll free Plan Sponsor Services number shown above.

ING MAP SelectSM

The ING Multiple Asset Portfolio Select (MAP Select) Group Funding Agreementfor Allocated Plan Accounts

Plan Sponsor Information

S.S.MT.1-2 (12/07)

1

P L A N S P O N S O R I N F O R M A T I O NING MAP SelectSM

The ING Multiple Asset Portfolio Select (MAP Select) Group FundingAgreement for Allocated Plan Accounts S.S.MT.1-2 (12/07)

Why Reading this Information Booklet is Important. This ING

Multiple Asset Portfolio Select (MAP Select) information booklet and the accompanying Additional Disclosure

Supplement (the Supplement) togetherprovide facts about the contract and its investment options and other important information. As the plan sponsor, youshould read these materials to help determine if the contract is appropriatefor your plan. Please keep these documents for future reference.

OVERVIEW

The MAP Select group fundingagreement* (hereafter generallyreferred to as a contract) offered by ING Life Insurance and Annuity Company (the Company, we, us, our) is the latest in our Multiple Asset Portfolio products that have been offered to fund retirement plans during the last three decades. The plan accounts in MAP Select offer employer-sponsored plans a comprehensive investment and benefit payment program, with flexible billing arrangements. Allocated MAP Select is suitable for almost all qualified defined contribution retirement plan types. This includes 401(k), profit sharing, money purchase pension and target benefit plans.

This booklet contains a summary of the key provisions of the allocated group contract. Minimum first year contribution and transferred asset amounts are required for eligibility. In addition, all scheduled contribution and employee enrollment information must use one of our standard automation methods during and after the contract installation. The actual eligibility requirements for the MAP Select allocated product, including all contract charges that would apply to your plan, are described in a customized proposal and in separate disclosure material. Other productfeatures and options are separately described.

Read on to find why the MAP Select allocated product is the right contract for your plan.

*Sold as a group annuity contract in the state of Washington.

ABOUT THE COMPANY

The Company issues the contract described in this booklet and provides administrative services. We are a stock life insurance company organized under the insurance laws of the State of Connecticut in 1976 and an indirect wholly-owned subsidiary of ING Groep N.V., a global financialinstitution active in the fields of insurance, banking and asset management. Securities are distributed through and financial planning is offered by ING Financial Advisers, LLC-member of the Securities Investor Protection Corporation (SIPC), and other broker-dealers with which theCompany has selling agreements.

THE MAP SELECT ALLOCATED FUNDING AGREEMENT

The contract described in this booklet is designed to fund qualified 401 corporate plans (including those of employers that have elected Subchapter S tax status) or planssponsored by employers of governmental and tax-exemptorganizations and self-employed plans that meet certain requirements. Contracts generally are issued to the trustees of a single plan, directly to a plan sponsor using a passive trustee for non-discretionary directed trustee services, or may be issued to a collective trust to fund multiple employers' retirement plans.

MAP Select features a variable pricing structure designed to reflect the actual services and distribution costsassociated with a retirement plan. The Company issues a group fundingagreement to cover all current and future participants under the sponsor's

retirement plan. This flexible payment contract can accept ongoing contributions and assets accumulated under this or a prior retirement plan.We also make available an information booklet for employees at their enrollment. That booklet describes the basic features of the allocated MAP Select contract.

THE MAP SELECT PLAN ACCOUNTS

Under the contract, we maintainallocated plan accounts for the following: individual participants enrolled under the contract (participant accounts), participants who separate from service with their employer (separated employee accounts), and the contract holder (trustee accounts). Multiple source records may be established for each plan account type (participant, separated employee or trustee), to track different types of employer and employee contributions (elective deferral, voluntary, employer match, etc.). Additionally, one sourcerecord will be established to accommodate pre-tax participant rollovers from other sponsored plansand from IRAs. Additional sourcerecords to accommodate post-taxrollover amounts are also available.

THE MAP SELECT INVESTMENT OPTIONS

Variable Investment Options

The MAP Select product offers a widerange of variable fund investment options in the contract, across all asset classes. MAP Select also offers a self-directed brokerage account (SDBA)option available as an accompaniment to the contract. Additional details on SDBA, including eligibility and costs,are provided separately.

Options in the contract are variable and involve investment risks. Contract values accumulating under any variable investment option will

2

fluctuate as the investment performance of the fund fluctuates. When contributions are allocated to a variable fund, shares of that fund are purchased by the Company and held in a pooled separate account. The separate account actually holds the fund shares. Your contract holds units of participation in the separate account.Some of these separate accountholdings may include different share classes within the same fund family.Different funds and fund share classes pay varying levels of fees to theCompany. Pricing for your plan takes these different fee levels into consideration and the different fee levels can provide flexibility in your overall cost. As a result, it is possible that different share classes within a fund family, or across different fund families, may be utilized in offeringthe variable investment options to your plan.

The variable investment options for your plan are described in the separate disclosure material and in fund prospectuses. A prospectus on each fund that you select for the plan will be provided and prospectuses for all funds offered under the contract are available at any time upon request. Unless otherwise arranged, we do not provide fund prospectuses directly to participants. Plan participants receive fund fact sheets. At our discretion, we may add, restrict, or withdraw the availability of investment options in the future. Certain restrictions may apply to the type and number of investment options selected for the plan, as described in the separate material.

The valuation of the variable investment options is dependent upon the securities markets. The applicable valuation date for fund transactions is subject to federal securities laws and regulations. Also, certain funds may deduct redemption fees to discourage market timing and other short-term

trading strategy. (See “Redemption Fees” in the Supplement.)

You should consider the investment

objectives, risks, and charges and

expenses of the variable product and

its underlying fund options offered

through a retirement plan carefully

before investing. The information

booklet and fund prospectuses

contain this and other information

and can be obtained by contacting

your local representative. Please

read the information carefully

before investing.

Credited Interest Options

MAP Select offers two different credited interest options. Only one option may be selected at one time under the contract. The Company's claims-paying ability should be taken into consideration in evaluating interest rate guarantees. The guarantee does not apply to the investment return or principal value of the variable investment options.

ING Fixed Account

The ING Fixed Account (Fixed Account) is generally a requiredinvestment option under the contract.

The Fixed Account provides stability of principal and credits interest on amounts allocated to this option. There are two kinds of guaranteed interest rates:

• Minimum guaranteed interest rate: We guarantee that interest will be credited at an annual effective yield that is no less than 1% and no greater than 3%. The minimumguaranteed interest rate isestablished for each calendar year and applies to all contracts issued during that year. It is guaranteed for the life of the contract.

• Floor interest rate: Each calendar year (1/1 to 12/31), the Company

will set a guaranteed floor interestrate. This rate will never be less than the minimum guaranteed interest rate. The floor interest rate will be declared in writing, to the contract holder, prior to its effective date. During the year, we may credit interest at a rate greater than this one-year rate.

The minimum guaranteed interest rate, the floor interest rate and the current credited interest rate (that we may change at any time) are each expressed as an annual effective yield. Interest is credited to accounts on a daily basis. Once credited, the interest becomes a part of principal. This means that plan accounts earn compound interest. Taking the effect of compounding into account, the interest credited daily yields the current credited interest rate. Any changes in rates will apply to all amounts in the Fixed Account.

The current credited interest rate is based on plan-specific characteristics, plan-specific elections, compensationpaid to sales professionals and other factors. If those plan-specific elections and characteristics change, we may make corresponding adjustments to the current and floor interest rates, subject to the guarantees described above.

Fixed Account interest could be reduced if the plan allows participants investment options not provided under the contract (split-funded plans), or in-service withdrawals prior to age 59½. There are restrictions on transfers from the Fixed Account and a positive or negative Market Value Adjustment (MVA) may apply on contract surrenders. See "Transfers from the Fixed Account" and "Payment of Surrender Value from the Fixed Account" and the exhibit included in the Appendix for complete details.

3

ING Guaranteed Accumulation Account

The ING Guaranteed Accumulation Account (GAA) option (not available

for all plans and not available in

Minnesota) offers interest rates that will be credited for guaranteed terms of ten years or less. During a deposit period, usually a calendar month, contributions may be allocated into guaranteed terms in the short-termclassification (terms of three years or less), or into guaranteed terms in the long-term classification (terms of ten years or less, but greater than three). We will determine, in advance, the rates of interest that will be earned and the duration of each guaranteed term offered during a deposit period.

A positive or negative MVA may be applied to amounts surrendered or transferred prior to the end of a guaranteed term. The accompanying disclosure booklet describes GAA in detail. If GAA is selected, the Fixed Account is not available.

404(c) PROTECTION

The Employee Retirement Income Security Act (ERISA) imposes a "prudent man" standard of investment selection and monitoring on employers and other pension plan fiduciaries.Plan fiduciaries can be held liable for investment losses if they don't invest plan assets prudently. However, Section 404(c) of ERISA provides limited relief from liability in participant-directed individual account plans where the plans' investment options meet special conditions.

The variable investment options offered under MAP Select allow plan fiduciaries to take advantage of the 404(c) protection. Depending on the combination of funds selected, the investment options can qualify as "core funds" under the 404(c) rules since they are broadly diversified, have different risk/return characteristics, are

supported by pre- and post-enrollmentdisclosure material, are valued and accessible daily, and are look-throughinvestment vehicles (mandatory for employees with small account balances). The Fixed Account and GAA are designed to be additional investments (not 404(c) core funds) which, in combination with the variable fund options, provide contract holders with both a well-roundedportfolio and 404(c) protection without the need for outside investment managers. Because 404(c) protection depends on the plan sponsor's selection of core funds and providing participants with appropriate disclosures, we cannot ensure compliance with 404(c). Rather, our responsibility is to carry out the investment instructions received fromthe contract holder and/or participants in accordance with applicable federal and state requirements.

Although the contract can provide employers and trustees with 404(c) protection, it is important to understand that the Company is not a designated fiduciary or investment manager for any retirement plan, since we have no discretionary authority over the plan or its investments. The employer/sponsor has overall fiduciary responsibility for its plan. You should discuss the requirements for 404(c) protectioncarefully with your legal adviser. Among other things, plan fiduciaries are responsible for additional disclosures beyond those provided by us in connection with the contract. For example, you must tell participants in writing that you will be relying on404(c) protection, and deliver fund prospectuses to participants.

ROLES OF THE COMPANY AND THE PLAN SPONSOR

With MAP Select our objective is to provide you and your employees with afunding vehicle that makes retirementplans easier. One of the ways we do this is by focusing on financial

transactions on your behalf and providing you and your employees thorough yet easy-to-read statements and summaries of the terms and conditions that apply to all of the contract investment options.

Plan administration responsibilities are critical for the proper maintenance of your plan. Although some employers may decide to administer their own plans without outside assistance, we recommend that you consider hiring a Third Party Administrator (TPA) or consider the ING Plan Services Agreement. Either approach can assist you with the technicalities of plan operation, to prepare your plan documents and employee plan disclosure and to keep vesting and other support records for your plan. A comprehensive description of the INGPlan Services Agreement, including full descriptions of services and charges, can be provided to you by your sales representative. Plans must meet minimum asset requirements to use the ING Plan Services Agreement.The agreement with your TPA will outline the services to be provided by your TPA and the TPA fees for such services.

It is important to understand that while we will provide many services for you and your participants, the Company is not your plan administrator and does not assume a discretionary or fiduciary role on behalf of your plan. As the plan sponsor, you will always be responsible for things like:

• maintaining overall plan design and operation;

• choosing plan investment options;

• appointing a TPA or using the ING Plan Services Agreement toensure plan compliance with federal qualification requirements;

• providing the Company or yourTPA with employee data, contribution information and beneficiary designations;

4

• reviewing your plan, summary plan description and other plan documents with legal counsel;

• maintaining records provided by us and your TPA;

• administering your plan in accordance with the requirements of ERISA and tax rules;

• communicating your plan to employees (e.g., distributing disclosure material and answering employee questions);

• making plan contributions on a timely and good order basis using one of our standard automation methods;

• reviewing and reconciling payroll contribution information with contract investment reports;

• providing the Company and your TPA with new enrollee and contribution change information to facilitate re-enrollments;

• authorizing plan disbursements and forfeiture allocations;

• ensuring accuracy of information provided; and

• assuring participant enrollment information or fund mapping instructions are provided to us before contributions are allocated to accounts.

Unless electing an ING Plan Services Agreement, we'll provide you with certain data required by regulations to aid you in preparing your annual report (IRS form 5500) but we do notcomplete the form for you. In addition, the only records we maintain on your plan's behalf are those shown in your quarterly statements. We do not maintain information on participant vesting, cost basis, loan repayment schedules, and other plan activity that may be needed depending on the transactions made under your plan.

It is also important to understand that our sales representatives are not authorized to make binding commitments on behalf of the Company. Our obligations are

governed by the contract, once it's issued by our Home Office and delivered to you.

SELECTING CONTRACT INVESTMENT OPTIONS

At any time, you (or participants if you so permit) may change the investment options to which new contributions will be applied. There is generally no limit on the number of changes that can be made, unless you limit them under the terms of your plan.

CHANGING CONTRACT INVESTMENT SELECTIONS

Transfers among the investment options may be made at any time. There is generally no limit on the number of transfers that can be made from the variable investment options, unless you limit them under the terms of your plan or unless transfers are limited because of the ExcessiveTrading Policy (see below). For plans selecting GAA, there are some transfer restrictions that are disclosed in the GAA booklet.

Confirmation of Changes

Transaction requests received in good order by the close of business of the New York Stock Exchange (normallyat 4:00 p.m. Eastern Time) areprocessed the same business day. You and your plan participants will receive confirmation statements and are advised that failure to report any discrepancy within 30 days will indicate agreement with the transactions made in the accounts as reported on confirmation statements.

Excessive Trading Policy

The Company has an ExcessiveTrading Policy and monitors transfer activity. See the Supplement for details.

Systematic Allocation

MAP Select provides a systematic allocation feature so that the plan participants may use "dollar cost averaging" or "account rebalancing." Under dollar cost averaging, participants may transfer amounts from one of the variable fund options available under the contract to another option within a selected source record in substantially equal installments. The amount applied must be no less than $100 per month over a period of at least 12 months (any period longer than 24 months requires prior approval). Account rebalancing allows participants to have variable fund options reallocated to specified percentages on a scheduled basis.Systematic allocations may not be made to or from the Fixed Account or GAA, except if authorized by us. Only one systematic allocation method may be in effect at any time and we reserve the right to limit the variable fund options that can be used for systematicallocations. Systematic allocation does not ensure a profit nor guarantee against loss. Investors should consider their financial ability to continue consistently investing in up as well as down markets. This feature is currently not available if electing an ING Plan Services Agreement.

TRANSFERS FROM THE FIXED ACCOUNT

Percentage Limitation or Equity Wash Option Election

An irrevocable election must be made on the contract application form, on whether transfers from the Fixed Account will use a percentage limitation or an equity wash option. Partial surrenders from the contract to a self-directed brokerage option arealso treated as transfers and are included in this irrevocable election. Both of these options are described in more detail below.

5

• Percentage Limitation Option

Limited transfers are permitted from the Fixed Account to any of the other investment options. The percentage permitted for transfer may vary at our discretion, but will never be less than 10% of the balance held in the Fixed Account on January 1 of a calendar year. The Company may allow a higher percentage up to 100%. However, if a participant has elected to transfer the maximum allowable amount from the Fixed Account in each of the four consecutive prior calendar years, and has not made any new contributions to the Fixed Account during that period, the participant is allowed to transfer the entire remaining balance. Also, if any plan account has less than $2,000 in the Fixed Account, the entire balance may be transferred to another available contract investment option.

• Equity Wash Option

If this option is elected for plans with no competing investment options, transfers from the Fixed Account can be made at any time from each plan account without limitations or restrictions. For plans that do have competing investment options, transfers are allowed at any time provided:

1. The Fixed Account transfer is not directed into a competing investment option;

2. A transfer into a competing investment option from any non-competing investment option has not occurred within 90 calendar days; and

3. A partial surrender has not occurred within 90 calendar days.

Transfers into a competing investment option from another investment option are allowed at

any time provided that no prior transfers from the Fixed Account have occurred within 90 calendar days.

A "competing investment option" is defined as any investment option under the MAP Select contract or other contract or investment program offered by the Company or its affiliates or other financial providers in connection with the plan that:

1. provides a direct or indirect guarantee of investment performance; or

2. is, or may be, invested primarily in assets other than common or preferred stock; or

3. is, or may be, invested primarily in financial vehicles, (such as mutual funds, trusts and insurance company contracts) which are invested in assets other than common or preferred stock.

In addition, the self-directed brokerage account option is considered a competing investment option. Competing investment options may not be immediately available on plans electing the equity wash option. Additional limitations on the movement of amounts from the Fixed Account may apply prior to any contract surrender.

CONTRACT CHARGES AND FEES FOR THE PLAN SPONSOR AND PARTICIPANTS

Contract Installation Charge

A one-time contract installation charge may be imposed on both the plan sponsor and the participants. The amount of the installation charge will appear in your MAP Select contractand the explanation as to how it is determined appears in your proposal. If applicable, the plan sponsor installation charge must be paid separately with the signed application.The installation charge for the

participants will be uniformly deducted from the participant accounts after the initial transferred asset contribution(s) is applied. The maximum one-timeinstallation charge for each participant with initial transferred assets is $100. Additional options may be available as explained in the separate disclosure material.

Account Maintenance Fees

Account fees reimburse the Company for some of its administrative expenses relating to the establishment and maintenance of plan accounts. Account fees may apply to the contract at the plan sponsor level and for participantsduring each contract year. The account fee is ordinarily deducted on a quarterly frequency, three months following the initial contribution made to the contract. As an alternative, the plan sponsor may, in accordance with our administrative practices, elect to pay the fee directly to us, or at contract installation elect to pay the fee as an increase to the contract's Daily Asset Charge.

The maximum quarterly fee for each participant for whom an account is established under the contract is $25. Since all enrollment information and contribution instructions must be submitted using one of our standard automation methods, the contract holder will generally be eligible for an account fee reduction in accordance with our administrative practices. The amount of account fee reduction could change at any time. An experience credit equal to the contract's annual account fee may apply, in accordance with our experience rating practice. The initial quarterly account fee for the plan sponsor and for each participant and the designated source record if it is to be deducted from participantaccounts will appear in your MAP Select contract.

If account fees are to be deducted from participant accounts, they are deducted

6

from the source record designated by us proportionately from all investment options. The amount of the quarterly account fee may be changed by the Company, following the review of the initial transferred assets and during the annual contract review.

Transferred Asset Benefit (TAB) Recovery Charge and ContractSurrender Charge

Under specific conditions, when authorized by state insurance law, we may reimburse a plan wholly or in part for any exit charge assessed by another financial provider by crediting an additional amount to the assets transferred to us from the investment vehicle of the other provider. We will recover this credit through an increase in the Daily Asset Charge, a reduced credited interest rate on the Fixed Account and by implementing a 1 to 7year TAB recovery charge schedule.

Minimum asset requirements apply and more complete details can be provided upon request. Any request for a TAB from a qualifying plan sponsor must be pre-approved by our Home Office prior to the contract installation.

A 1 to 7 year contract surrender charge schedule may apply, depending on theplan specific characteristics. Both the TAB recovery charge and/or the contract surrender charge, ifapplicable, will appear in your MAPSelect contract. Charges are calculatedas a percentage of the amount withdrawn and are assessed so we may recover a portion of our sales and administration expenses. If a charge applies, the percentage would be determined by the number of completed contract years between the date the first contribution is applied to the contract and the date of the surrender.

The primary purpose of the MAP Select contract is to provide retirement income benefits for plan participants.

Accordingly, no TAB recovery charge or contract surrender charge is assessed against withdrawals taken for reasons of participant retirement, severance from employment, hardship, loan, death, disability or in-servicewithdrawal after age 59½. Generally, these are the only conditions where a participant-initiated withdrawal may be permitted under the contract.

DAILY ASSET CHARGE ANDVARIABLE FUND EXPENSES

Contributions invested in the variable investment options will generally be subject to a Daily Asset Charge. Each of the variable funds also includes separate expenses, as described in the fund fact sheets and in the fundprospectuses. The revenue the Company receives from the variable funds and the Daily Asset Charge reimburses us for a portion of our marketing and sales expenses as well as the costs of the many services provided by the Company and its representatives (e.g., the Call Centers and Internet account access, daily valuation systems, regulatory information, transaction processing, newsletters, sponsor and employee education and enrollment, etc.). Please refer to the Supplement for more information.

Daily Asset Charge (DAC)

The DAC is assessed against the variable funds and is expressed as an annual percentage. The applicable DAC will be based on plan-specificcharacteristics (plan assets, number of participants, etc.) and plan-specificelections (fund menu, investment elections, whether expenses are billed to the plan sponsor or not, level of marketing and distribution expenses, the extent to which plan fiduciaries direct us to pay TPA administration fees, etc.).

The MAP Select contract holder may elect additional services that will result

in increased DAC being assessed on the variable fund options and/or a lower credited interest rate on the Fixed Account. Also, there may be an administrative fund fee adjustment to the DAC depending on the fund menu chosen as described in the “Fund Revenue Sharing and Expense Disclosure” section of the Supplement.

The Daily Asset Charge will appear in the separate disclosures that your sales representative will provide to you. The DAC for the initial year, a schedule of the maximum DAC at specific plan asset breakpoints and if applicable, theDAC adjustments on the selected fund menu, will also appear in your MAPSelect contract.

The Company reserves the right to review and adjust the Daily Asset Charge on the contract year anniversary date. The DAC may be adjusted due to the attainment of a higher or lower plan assetaccumulation breakpoint, changes intotal investment selection, or in theaverage participant account balances or in other plan characteristics. The DACis also subject to adjustment if the initial transferred assets vary significantly from the assumptions on which the initial DAC was based. Changes in the DAC may also result in a change to the Fixed Account credited interest rate. The Company will generally provide advance written notice of a DAC adjustment but is not required to do so to actually implement an adjustment. The plan sponsor and the Company may agree that all or part of the DAC may be billed and paid separately.

The DAC may be increased for contracts that allow the participants investment options outside of the MAP Select contract (split-funded plans), and for plans that permit in-servicewithdrawals for participants before reaching age 59½.

7

The total DAC will never be less than 0.00%.

Fund Revenue Sharing, Fees andExpenses Disclosure

The total fund related expenses including the administrative fund fees are illustrated in the MAP Select Fund Performance and Expense Report.Additional information is available upon request.

For important information aboutinvestment advisory fees, redemptionfees, 12b-1 distribution fees and other expenses and disclosures on fund revenue sharing, refer to the Supplement and the applicable fund fact sheets.

SALES COMPENSATION DISCLOSURE

Please refer to the Supplement for salescompensation information.

CONTRACT SURRENDERS

Full and partial surrenders are satisfied by withdrawing amounts on a pro-ratabasis from all investment options available under a plan account. The contract holder, or participant, if applicable (allowed on split-fundedplans for example), may specify a particular order in which investment options can be withdrawn on a partial surrender request. However, any partial surrender including amounts from the Fixed Account must be paid pro-ratafrom all investment options and is limited to once per 90 days. If a surrender or TAB recovery charge is due, it will be deducted after any applicable Fixed Account or GAA MVA is deducted.

Any severance from employment must generate IRS tax reporting of the payment, and not result in a direct transfer of the participant's account balance by the employer to the new

employer's plan, in order to be regarded as a benefit.

PAYMENT OF SURRENDER VALUE FROM THE FIXED ACCOUNT

We will make an unadjusted lump-sumpayment from the Fixed Account for the purpose of paying a benefit (defined as being due to participant retirement, severance from employment, hardship, loan, death, disability or in-service withdrawal after age 59½). Such a withdrawal must be made proportionately from theparticipant's plan investment options. On all surrenders from the Fixed Account, we will pay the Fixed Account surrender value by using a Market Value Adjustment (MVA) or a scheduled payment method, as elected by the contract holder. More information on the Fixed Account MVA can be found in the Appendix.

CHANGES TO THE CONTRACT

The Company, through its authorized officers in the Home Office, may change the contract by giving written notice to the contract holder 30 days before the effective date of the change.We may change the contract at any time where such change is required by federal or state law, or where there are potential adverse financial effects to the contract resulting from a change made by the plan.

We may change certain contract provisions by giving 30 days' written notice. However, any such changeswill not apply to amounts held in existing plan accounts, but may apply only to contributions made to such accounts after any such change.

We may change the scheduled period of time payment option and table for such option by giving 30 days' written notice. Any change will not apply to amounts held in existing plan accounts, but will only apply to new participants

and contributions made on or after the change. Any change will not affect the amount or terms of any scheduledperiod of time option beginning before the change is effective.

We may change the MVA formula(s) in the contract by giving written notice to the contract holder at least 90 days prior to the effective date of the change. Any changes to the GAA MVA formula will apply only to new guaranteed terms established on or after the change is effective.

Where we propose a change to the contract requiring mutual agreement, if the contract holder does not agree to the change, no new participants will be covered by the contract. Also, in this situation, we may stop accepting additional contributions for the existing participants covered under the contract.

After the completion of five contract years, we may terminate the contract by providing the contract holder a 90-day written notice to pay out the full value without fees, charges or MVA.If agreed to by the contract holder, we may also transfer the full value that may be subject to charges or MVA to another contract offered by the Company or one of its affiliates.

PAYMENT PROVISIONS

To avoid certain tax penalties, distributions must begin in the form of periodic benefit payments no later than the April 1 following the calendar year in which the participant turns age 70½or retires, whichever occurs later. The contract holder must direct us to schedule a payment option or make a lump-sum payment.

Federal law, through the Retirement Equity Act (REA), generally requires that payments to married participants must have spousal consent. The contract holder must certify that any payment option (or pre-retirement

8

death benefit) elected complies with the provisions of REA.

PAYMENT OPTIONS

The contract holder may elect on behalf of the participant or a deceased participant's beneficiary under the plan the following payment options:

Lump-Sum Payment - We will pay a lump sum equal to all or any vested portion of the participant's account value.

Systematic Distribution Options

(SDO) - We provide several different systematic distribution options thatallow for scheduled withdrawals from a participant account. SDO payments are available, where allowed by the plan, to participants who meet certain age and account value requirements under the contract. More information on the available options can be provided on request.

The participant account remains in the accumulation phase under the contract. This means that transfers among investment options continue to be available, contract charges continue to apply and the lump-sum payment is still an available option.

Scheduled Period of Time Option* -

We provide a fixed interest option using the Company's general account that offers a guaranteed benefit stream of payments to participants. We alsoguarantee that interest will be credited at an annual equivalent yield that is at least equal to 1.50%. This guarantee is based on the claims-paying ability of the Company. The payment optionmade available to participants at retirement is called the scheduled period of time option. Under this option, periodic payments can be made for a fixed period of years that must be at least 5 and not more than 30.

The scheduled period of time optionelection is subject to the terms of the

plan and direction of the contract holder. A contract holder, on behalf of the participant, may not elect thisoption if the first payment would be less than $100 or if the total payments in a year would be less than $500. If the account value is insufficient to meet these minimum amounts, a lump sum payment must be elected. When payments start, the age of the participant plus the number of years for which payments are guaranteed may not exceed that permitted by the Internal Revenue Code minimum required distribution regulations. Once elected, scheduled payments can not be commuted to a lump sum.

Additional payment options may be made available to participants under a separate Company single premium immediate annuity contract.

*For a MAP Select group annuity contract (state of Washington only), we provide the Scheduled Period of Time option in the form of an annuity payment option.

DEATH BENEFIT UNDER THE CONTRACT

If the death of a retired participant occurs before all benefit payments are received under the scheduled period of time option, the designated beneficiarycan choose to either receive the remaining periodic payments or to have the present value of the payments paid in a lump sum.

If a plan participant dies before electing a scheduled period of timeoption, any benefits payable under the contract are payable to the contract holder, generally the plan trustees.

At the direction of the contract holder, we will pay a portion or all of the participant account value in a lump sum, or apply such amount to a SDO or scheduled period of time paymentoption for the participant's beneficiary under the plan.

Additional choices may be made available outside the contract for participant beneficiaries under a separate Company single premium immediate annuity contract.

DIRECT DEPOSIT

A direct deposit program for distributions paid directly to participants is available at no additional charge. Electronic Funds Transfer (EFT) is an electronic deposit of benefit payment(s) directly into aparticipant’s checking or savings account by an automated clearing house. This allows participants to receive their payment(s) more quickly than traditional check processingtimelines.

TAX INFORMATION

Under federal tax law, qualified 401 plan contributions and investment earnings are not taxable until they are distributed. Taxation occurs when amounts are paid from the contract to participants (or their beneficiaries) for benefits under the plan. The contract serves as the vehicle for such a plan, providing the investment and payment options and other features described in this booklet, but is not necessary for the plan's favorable tax treatment.

IRS Circular 230 Disclosure: These

materials are not intended to be used

to avoid tax penalties, and were

prepared to support the promotion

or marketing of the matter

addressed in this booklet. You

should seek advice from an

independent tax adviser.

SUSPENSION OF FINANCIAL TRANSACTIONS OR PAYMENT DELAY

In accordance with applicable federal securities laws and regulations, we reserve the right to suspend financial transactions or postpone payments from participant accounts during times

9

when the following situations may occur:

• The New York Stock Exchange (“NYSE”) is closed or trading on the NYSE is restricted, or

• The U.S. Securities and Exchange Commission (SEC) determinesthat a market emergency exists or restricts trading for the protection of investors.

The Company, under certain emergency conditions, may also defer any payment from the Fixed Account credited interest option for a period of up to 6 months.

CONTRACT DELIVERY AND ACCEPTANCE

The "APPLICATION FOR FUNDINGAGREEMENT"* will become part of your contract, once it is accepted by the Company at its Home Office. We reserve the right not to accept the application. The contract will be subject to the laws of the state in which it is delivered. The state of contractissue will generally be determined by the plan's primary business location and where the application is signed by the contract holder and our licensed sales representative. All contract ownership rights rest with the contract holder. Once delivered, it is important that you review the contract carefully.

This booklet and the accompanying Supplement contain a summary of the pertinent provisions of the contract. The contract is not subject to the claims of creditors except to the extent permitted by law. In the event of a conflict between this booklet (and/orthe Supplement) and the contract, the terms of the contract will prevail.

*For the state of Washington, an “APPLICATION FOR GROUP ANNUITY CONTRACT” is used.

QUESTIONS OR COMPLAINTS

To request information about this contract or if you have questions, please call Plan Sponsor Services toll-free at 888-410-9482.

Complaints? Please contact us at ING Life Insurance and Annuity Company,Contact Center – B2S, PO Box 99065Hartford, CT 06199-0065. Or, by telephone, you may call us at the toll-free Plan Sponsor Services number shown above.

10

APPENDIX

Market Value Adjustment - Fixed Account

On all surrenders from the Fixed Account, the Fixed Account surrender value will be paid in one of the following two ways, as elected by the contract holder:

(a) In equal principal payments, with interest, over a period not to exceed 60 months. During the payment period, the interest rate will be credited to the remaining Fixed Account balance at a single rate that is established at the start of the payment period and that will not be more than 1.50% below the rate being credited to the Fixed Account as of the date of surrender. In no event will the credited interest rate be less than the minimum guaranteed interest rate.

or

(b) As a single payment, which has been adjusted by a Fixed Account Market Value Adjustment (MVA). To determine the single payment amount, the total Fixed Account surrender value is multiplied by the MVA.

The MVA is calculated as follows:

MVA = 1 - [ (1 - ((1+a) 5.25 / (1+b) 5.25 )) (c) ]

Where: a is the Fixed Account standard credited rate (the median declared interest rate communicated monthly for this class of contract) as of the date of surrender; and

b is the rate for a 7-year Treasury Bond derived by interpolating between 5-year and 10-year TreasuryBond rates as found in the Citigroup Bond Market Roundup (if unavailable, a similar service will be utilized) for the week prior to the surrender, and

c is the percentage of Fixed Account surrender value to which the MVA applies.

% of Fixed Account surrender value to

Completed Contract Years* which the MVA applies ("c")*

Less than 1 0%1 but less than 2 20%2 but less than 3 40%3 but less than 4 60%4 but less than 5 80%

More than 5 100%

* The above MVA phase-in table may be different where an existing Company contract is converted to the MAP Select contract.

WWW.ING-USA.COM

Insurance products, annuities and funding agreements issued byING Life Insurance and Annuity Company (“ILIAC”) One OrangeWay,Windsor, CT 06095 , which is solely responsible for meetingits obligations. Plan administrative services provided by ILIAC orING Institutional Plan Services, LLC. All companies are membersof the ING family of companies. Securities distributed by oroffered through ING Financial Advisers, LLC (memberSIPC) or other broker-dealers with which it has a sellingagreement. Group Annuities and Funding Agreements arelong-term investment vehicles designed for retirement purposeswhich allow you to allocate contributions among variableinvestment options that have the potential to grow tax deferred,or in the case of Roth contributions, tax free, with an option toreceive a stream of income at a later date. Early withdrawalsmay be subject to surrender charges, and if taken prior to age591⁄2 , a 10% IRS penalty may apply. Taxes are due uponwithdrawal of tax deferred assets; withdrawals will also reducethe applicable death benefit and cash surrender value.

© 2010 ING North America Insurance Corporation

C10-0628-043R

For more informationplease contact:

INGOne Orange WayWindsor, CT 06095-4774

www.ing-usa.comwww.ingretirementplans.com

3016103.C.S 21 (7/10)

ing retirement plan

Documents

investment performance9

t h t e c h n o

flexible investment

fiduciary responsibilitiesand

retirement objectives

o g yl e

d i n g w

support tohelp