0001104659-09-046029 Sample Contracts

August 20, 2009 Ms. Mary Jean Milner Vice President The Bank of New York Mellon One Wall Street, 25th Floor New York, NY 10286 Dear Ms. Milner:
ING Separate Portfolios Trust • July 30th, 2009

Pursuant to the terms and conditions of the Custody Agreement, Foreign Custody Manager Agreement, Fund Accounting Agreement, Custody & Fund Accounting Fee Schedule, and Global Securities Fee Schedule, each dated January 6, 2003, and the Cash Reserve Agreement dated March 31, 2003 (the “Agreements”), we hereby notify you of the addition of ING Dow Jones Euro STOXX 50® Index Portfolio, ING FTSE 100 Index Portfolio, ING Japan Equity Index Portfolio, and ING Nasdaq 100 Index Portfolio (collectively, the “Portfolios”), each a newly established series of ING Variable Portfolios, Inc., to be included on the Amended Exhibit A to the Agreements as shown. This Amended Exhibit A supersedes the previous Amended Exhibit A dated August 19, 2009.

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TRANSFER AGENCY SERVICES AGREEMENT
Transfer Agency Services Agreement • July 30th, 2009 • ING Separate Portfolios Trust

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

FORM OF EXPENSE LIMITATION AGREEMENT ING Separate Portfolios Trust
Expense Limitation Agreement • July 30th, 2009 • ING Separate Portfolios Trust

This EXPENSE LIMITATION AGREEMENT (this “Agreement”), effective as of the 16th day of May, 2007, is made by and between ING Investment Management Co. (the “Investment Manager”) and ING Separate Portfolios Trust (the “Registrant”). The Registrant is a series fund investment company, and is entering into this Agreement on behalf of, and this Agreement shall apply to, each series of the Registrant set forth on Schedule A hereto (each a “Fund,” collectively the “Funds”), as such schedule may be amended from time to time to add or delete series.

AMENDED AND RESTATED ADMINISTRATION AGREEMENT
Administration Agreement • July 30th, 2009 • ING Separate Portfolios Trust • Delaware

THIS AGREEMENT made this 16th day of May, 2007, as amended and restated on November 30, 2008, between ING Separate Portfolios Trust (the “Trust”), a Delaware statutory trust, and ING Funds Services, LLC (the “Administrator”), a limited liability company organization under the laws of Delaware.

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