0001104659-12-084990 Sample Contracts

FORM OF
ING Separate Portfolios Trust • December 18th, 2012
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FORM OF EXPENSE LIMITATION AGREEMENT ING SEPARATE PORTFOLIOS TRUST
Expense Limitation Agreement • December 18th, 2012 • ING Separate Portfolios Trust

This EXPENSE LIMITATION AGREEMENT (this “Agreement”), effective this 20th day of July 2012, by and between ING Investments, LLC (the “Investment Manager”) and ING Separate Portfolios Trust (the “Registrant” or the “Trust”). 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.

December 19, 2012 Christopher Kurtz Vice President ING Investment Management Co. LLC One Orange Way, C1-N Windsor, CT 06095 Dear Mr. Kurtz:
Sub-Advisory Agreement • December 18th, 2012 • ING Separate Portfolios Trust

Pursuant to the Sub-Advisory Agreement (the “Agreement”), dated July 20, 2012 between ING Investments, LLC and ING Investment Management Co. LLC (“Sub-Adviser”), as amended, we hereby notify you of our intention to retain you as Sub-Adviser to render investment advisory services to ING Retirement Solution 2020 Fund, ING Retirement Solution 2025 Fund, ING Retirement Solution 2030 Fund, ING Retirement Solution 2035 Fund, ING Retirement Solution 2040 Fund, ING Retirement Solution 2045 Fund, ING Retirement Solution 2050 Fund, ING Retirement Solution 2055 Fund, and ING Retirement Solution Income Fund (collectively, the “Funds”), each a newly established series of ING Separate Portfolios Trust, effective on December 19, 2012, upon all of the terms and conditions set forth in the Agreement.

December 19, 2012 Todd Modic Senior Vice President ING Funds Services, LLC
ING Separate Portfolios Trust • December 18th, 2012
December 19, 2012
Underwriting Agreement • December 18th, 2012 • ING Separate Portfolios Trust
December 19, 2012 Todd Modic Senior Vice President ING Investments, LLC Suite 100 Scottsdale, AZ 85258 Dear Mr. Modic:
Investment Management Agreement • December 18th, 2012 • ING Separate Portfolios Trust

Pursuant to the Investment Management Agreement (the “Agreement”), dated July 20, 2012, as amended, between ING Separate Portfolios Trust and ING Investments, LLC (“Manager”), we hereby notify you of our intention to retain you as Manager to render investment advisory services to ING Retirement Solution 2020 Fund, ING Retirement Solution 2025 Fund, ING Retirement Solution 2030 Fund, ING Retirement Solution 2035 Fund, ING Retirement Solution 2040 Fund, ING Retirement Solution 2045 Fund, ING Retirement Solution 2050 Fund, ING Retirement Solution 2055 Fund, and ING Retirement Solution Income Fund (collectively, the “Funds”), each a newly established series of ING Separate Portfolios Trust, effective on December 19, 2012, upon all of the terms and conditions set forth in the Agreement.

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