Exhibit (d)(18)
[ING FUNDS LOGO]
February 11, 2004
▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇
President
ING Partners, Inc.
▇▇▇▇ ▇▇▇▇ ▇▇▇▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇▇▇▇
▇▇▇▇▇▇▇▇▇▇, ▇▇▇▇▇▇▇ ▇▇▇▇▇-▇▇▇▇
Re: ING Partners, Inc. (the "Fund")
Dear ▇▇. ▇▇▇▇▇▇▇▇:
By our execution of this letter agreement (the "Agreement"), intending to
be legally bound hereby, ING Funds Services, LLC ("ING Funds Services"), the
Fund's Administrator, agrees that in order to increase the competitiveness of
the established expense ratios of the ING American Century Small Cap Value
Portfolio and the ING Baron Small Cap Growth Portfolio of the Fund, ING Funds
Services shall, from May 1, 2004 through April 30, 2005, waive all or a portion
of its administrative services fee and/or reimburse expenses in amounts
necessary so that after such waivers and/or reimbursements, the maximum total
operating expense ratios of the ING American Century Small Cap Value Portfolio
shall not exceed 1.30%, 1.55% and 1.80% for the Initial, Service and Adviser
class shares respectively and the maximum total operating expense ratios of the
ING Baron Small Cap Growth Portfolio shall not exceed 1.20%, 1.45% and 1.70% for
the Initial, Service and Adviser class shares respectively of the respective
Portfolio's average daily net assets.
ING Funds Services acknowledges that (1) it shall not be entitled to
collect on or make a claim for waived fees at any time in the future, and (2) it
shall not be entitled to collect on or make a claim for reimbursed expenses at
any time in the future.
ING Funds Services, LLC
By: /s/ ▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇
---------------------
▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇
Executive Vice President
Your signature below acknowledges
acceptance of this Agreement:
By: /s/ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇
---------------------
▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇
President
ING Partners, Inc.
▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇▇. Tel: ▇▇▇-▇▇▇-▇▇▇▇ ING Funds Services, LLC
Scottsdale, AZ ▇▇▇▇▇-▇▇▇▇ Fax: ▇▇▇-▇▇▇-▇▇▇▇
▇▇▇.▇▇▇▇▇▇▇▇.▇▇▇
