0001193125-07-093851 Sample Contracts

April 30, 2007 Ms. Mary Jean Milner Vice President The Bank of New York
Ing Variable Funds • April 27th, 2007

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 BlackRock Inflation Protected Bond Portfolio, ING Franklin Mutual Shares Portfolio, and ING Franklin Templeton Founding Strategy Portfolio, three newly established series of ING Investors Trust (the “Funds”), effective April 30, 2007, to be included on the Amended Exhibit A to the Agreements as shown. This Amended Exhibit A supersedes the previous Amended Exhibit A dated March 27, 2007.

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SECOND AMENDMENT TO SUB-ADVISORY AGREEMENT ING VARIABLE FUNDS
Sub-Advisory Agreement • April 27th, 2007 • Ing Variable Funds

This Second Amendment, effective as of January 1, 2007, amends the Sub-Advisory Agreement (the “Agreement”) dated the 1st day of March 2002, as amended, between ING Investments, LLC, an Arizona limited liability company (the “Manager”) and ING Investment Management Co. (formerly Aeltus Investment Management, Inc.), a Connecticut corporation (the “Sub-Adviser”).

AMENDMENT TO INVESTMENT MANAGEMENT AGREEMENT ING VARIABLE FUNDS
Investment Management Agreement • April 27th, 2007 • Ing Variable Funds

This Amendment, effective as of January 1, 2007, amends the Investment Management Agreement (the “Agreement”) dated the 1st day of March 2002, between ING Investments, LLC, an Arizona limited liability company (the “Manager”) and ING Variable Funds (formerly Aetna Variable Fund), a Massachusetts business trust (the “Fund”).

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