485BPOS

As filed with the Securities and Exchange	Registration No. 333-56297
Commission on November 13, 2007	Registration No. 811-02512

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION 

Washington, D.C. 20549

FORM N-4

Post-Effective Amendment No. 35 To

REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 

and Amendment to

REGISTRATION STATEMENT UNDER THE INVESTMENT COMPANY ACT OF 1940 

Variable Annuity Account B

of

ING Life Insurance and Annuity Company

151 Farmington Avenue, TS31

Hartford, Connecticut 06156

Depositor’s Telephone Number, including Area Code: (860) 723-2239 

John S. (Scott) Kreighbaum, Esq.

ING

1475 Dunwoody Drive

West Chester, PA 19380-1478

(610) 425-3404

(Name and Address of Agent for Service)

Approximate Date of Proposed Public Offering:
As soon as practical after the effective date of the Registration Statement

It is proposed that this filing will become effective:

[X]	immediately upon filing pursuant to paragraph (b) of Rule 485
[ ]	On [ ] [ ], 2007 pursuant to paragraph (b) of Rule 485

If appropriate, check the following box:

	this post-effective amendment designates a new effective date for a previously filed
[ ]	post-effective amendment.

Title of Securities Being Registered: Group or Individual Deferred Variable Annuity Contracts

EXPLANATORY NOTE: Each of the Prospectus and Statement of Additional Information, dated
April 30, 2007 and as supplemented, is incorporated into Parts A and B, respectively, of this
amendment by reference to Post-Effective Amendment No. 34 to this Registration Statement, as filed
on April 20, 2007 (Accession No. 0000103005-07-000024). This amendment further supplements the
prospectus and does not otherwise delete, amend, or supersede any other information in this registration
statement, as previously amended, including exhibits and undertaking.

SUPPLEMENT Dated November 12, 2007 

To The Prospectus Dated April 30, 2007 For 

ING Variable Annuity

Issued By ING Life Insurance and Annuity Company 

Through Its Variable Annuity Account B

This supplement updates the current prospectus for your variable annuity contract. Please read it carefully
and keep it with your copy of the prospectus for future reference. If you have any questions, please call our
Customer Contact Center at 1-800-366-0066.

On July 24, 2007, the Board of Directors of ING Variable Portfolios, Inc. approved a proposal to reorganize
the ING VP International Equity Portfolio into the ING VP Index Plus International Equity Portfolio.
Subject to approval by each Portfolio’s shareholders, after the close of business on November 9, 2007 the
following Disappearing Portfolios will reorganize into and become part of the following Surviving Portfolio:

Disappearing Portfolio	Surviving Portfolio
ING VP International Equity Portfolio (Class I)	ING VP Index Plus International Equity Portfolio
	(Class I)
ING VP Index Plus International Equity Portfolio	ING VP Index Plus International Equity Portfolio
(Class S)	(Class I)

Accordingly, effective after the close of business on November 9, 2007, investments in the Disappearing
Portfolios will automatically become investments in the Surviving Portfolio. As a result, effective November
12, 2007 all references to the Disappearing Portfolios in the Prospectus are hereby deleted.

Unless you provide us with alternative allocation instructions, all future allocations directed to the
Disappearing Portfolios after the date of the reorganizations will be automatically allocated to the Surviving
Portfolio. You may give us alternative allocation instructions at any time by contacting our service center at:

Customer Service Center
909 Locust Street
Des Moines, IA 50309-2899
1-800-366-0066

See also the “Transfers Among Your Investment Options (Excessive Trading Policy)” section of your
Prospectus for further information about making fund allocation changes.

The following information is added to the “Appendix III – Description of Underlying Funds” section of the
prospectus:

Fund Name and
Investment Adviser/Subadviser	Investment Objective
ING Investors Trust
7337 E. Doubletree Ranch Road, Scottsdale, AZ 85258
ING VP Index Plus International Equity Portfolio	Seeks to outperform the total return performance of the
	Morgan Stanley Capital International Europe Australasia and
Investment Adviser: ING Investments, LLC	Far East® Index (“MSCI EAFE® Index”), while maintaining a
Subadviser: ING Investment Management Advisors,	market level of risk. The Portfolio’s investment objective is
B.V.	not fundamental and may be changed without a shareholder
	vote.

146343 – Variable Annuity  Page 1 of 2  November 2007 

IMPORTANT INFORMATION REGARDING UPCOMING 

FUND LIQUIDATION

On July 12, 2007, the Board of Trustees of ING Investors Trust approved a proposal to liquidate the:
· ING MarketPro Portfolio.

The proposed liquidation is subject to shareholder approval. If shareholder approval is obtained, it is
expected that the liquidation will take place on or about November 10, 2007 (the “Closing Date”).

Voluntary Transfers Before the Closing Date. Anytime prior to the Closing Date you may transfer
amounts that you have allocated to the subaccounts that invest in the ING MarketPro Portfolio to any of the
other available investment options. There will be no charge for any such transfer, and any such transfer will
not count as a transfer when imposing any applicable restriction or limit on transfers. You may give us
alternative allocation instructions at any time by contacting the ING Customer Service Center at 909 Locust
Street, Des Moines, IA 50309-2899, 1-800-366-0066. See also the “Transfers Among Investment
Options (Excessive Trading Policy)” section of your prospectus for further information about making
fund allocation changes.

Automatic Reallocation Upon Liquidation. After the Closing Date and our receipt of the proceeds from
the liquidation of the ING MarketPro Portfolio, amounts that were allocated to the subaccounts that invested
in this portfolio will be automatically reallocated to the subaccount that invests in the ING VP Money Market
Portfolio. There will be no charge for this automatic reallocation, and this automatic reallocation will not
count as a transfer when imposing any applicable restriction or limit on transfers. Furthermore, you will not
incur any tax liability because of this automatic reallocation, and your contract value immediately before the
reallocation will equal your contract value immediately after the reallocation.

Future Allocations. After the Closing Date, the subaccounts that invested in the ING MarketPro Portfolio
(Class S) will be no longer available through your contract. Any future allocations directed to a subaccount
that invested in one of this portfolio will be automatically allocated to the subaccount that invests in the ING
VP Money Market Portfolio.

Information about the ING VP Money Market Portfolio. Summary information about the ING VP
Money Market Portfolio can be found in Appendix III of your prospectus. More detailed information can be
found in the current prospectus for that fund. You may obtain these documents by contacting the ING
Customer Service Center at 909 Locust Street, Des Moines, IA 50309-2899, 1-800-366-0066.

There will be no further disclosure regarding the ING MarketPro Portfolio in future prospectuses of the
contract.

146343 – Variable Annuity  Page 2 of 2  November 2007 

PART C - OTHER INFORMATION

Item 24. Financial Statements and Exhibits:
(a) Financial Statements:
(1)	Included in Part A:
	Condensed Financial Information
(2)	Included in Part B:
	Consolidated Financial Statements of ING Life Insurance and Annuity Company:
	-	Report of Independent Registered Public Accounting Firm
	-	Consolidated Statements of Operations for the years ended December 31, 2006, 2005
		and 2004
	-	Consolidated Balance Sheets as of December 31, 2006 and 2005
	-	Consolidated Statements of Changes in Shareholder’s Equity for the years ended
		December 31, 2006, 2005 and 2004
	-	Consolidated Statements of Cash Flows for the years ended December 31, 2006, 2005
		and 2004
	-	Notes to Consolidated Financial Statements
	Financial Statements of Variable Annuity Account B:
	-	Report of Independent Registered Public Accounting Firm
	-	Statements of Assets and Liabilities as of December 31, 2006
	-	Statements of Operations for the year ended December 31, 2006
	-	Statements of Changes in Net Assets for the years ended December 31, 2006 and 2005
	-	Notes to Financial Statements

(b)	Exhibits:
	(1)	Resolution establishing Variable Annuity Account B · Incorporated by reference to Post-
		Effective Amendment No. 6 to Registration Statement on Form N-4 (File No. 33-75986),
		as filed on April 22, 1996.
	(2)	Not applicable.
	(3.1)	Standard Form of Broker-Dealer Agreement · Incorporated by reference to Post-
		Effective Amendment No. 32 to Registration Statement on Form N-4 (File No. 33-
		81216), as filed on April 11, 2006.
	(3.2)	Underwriting Agreement dated November 17, 2000 between Aetna Life Insurance and
		Annuity Company and Aetna Investment Services, LLC · Incorporated by reference to
		Pre-Effective Amendment No. 1 to Registration Statement on Form N-4 (File No. 333-
		49176), as filed on November 30, 2000.
	(3.3)	Confirmation of Underwriting Agreement · Incorporated by reference to Post-Effective
		Amendment No. 32 to Registration Statement on Form N-4 (File No. 33-81216), as filed
		on April 11, 2006.
	(3.4)	Form of Rule 22c-2 Agreement · Incorporated herein by reference to Post-Effective
		Amendment No. 10 to Registration Statement on Form N-4 (File Nos. 333-115515), as
		filed on April 12, 2007.
	(4.1)	Variable Annuity Contract (GM-VA-98) · Incorporated by reference to Registration
Statement on Form N-4 (File No. 333-56297), as filed on June 8, 1998.
	(4.2)	Variable Annuity Contract Certificate (GMC-VA-98) · Incorporated by reference to
		Registration Statement on Form N-4 (File No. 333-56297), as filed on June 8, 1998.
	(4.3)	Variable Annuity Contract (GM-VA-98(NY)) · Incorporated by reference to Post-
		Effective Amendment No. 18 to Registration Statement on Form N-4 (File No. 333-
		56297), as filed on August 30, 2000.

(4.4)	Variable Annuity Contract Certificate (GMC-VA-98(NY)) · Incorporated by reference to
	Post-Effective Amendment No. 18 to Registration Statement on Form N-4 (File No. 333-
	56297), as filed on August 30, 2000.
(4.5)	Endorsement (EVAGET98) to Variable Annuity Contract GM-VA-98 and Variable
	Annuity Contract Certificate GMC-VA-98 · Incorporated by reference to Post-Effective
	Amendment No. 1 to Registration Statement on Form N-4 (File No. 333-56297), as filed
	on September 14, 1998.
(4.6)	Endorsement (EGET-99) to Variable Annuity Contract GM-VA-98 and Variable Annuity
	Contract Certificate GMC-VA-98 · Incorporated by reference to Post-Effective
	Amendment No. 13 to Registration Statement on Form N-4 (File No. 333-01107), as
	filed on April 7, 1999.
(4.7)	Endorsement (EVA-PB-00) to Variable Annuity Contract GM-VA-98 and Variable
	Annuity Contract Certificate GMC-VA-98 · Incorporated by reference to Post-Effective
	Amendment No. 15 to Registration Statement on Form N-4 (File No. 333-56297), as
	filed on May 8, 2000.
(4.8)	Endorsement (EVA-PB-00 (NY)) to Variable Annuity Contract GM-VA-98(NY) and
	Variable Annuity Contract Certificate GMC-VA-98(NY) · Incorporated by reference to
	Post-Effective Amendment No. 21 to Registration Statement on Form N-4 (File No. 333-
	56297), as filed on December 13, 2000.
(4.9)	Endorsements ENMCHG (05/02) and ENMCHGI (05/02) for name change ·
	Incorporated by reference to Post-Effective Amendment No. 30 to Registration Statement
	on Form N-4 (File No. 33-75962), as filed on April 8, 2002.
(5)	Variable Annuity Contract Application (9.5.89-6(9/98)) · Incorporated by reference to
	Pre-Effective Amendment No. 1 to Registration Statement on Form N-4 (File No. 333-
	56297), as filed on August 4, 1998.
(6.1)	Restated Certificate of Incorporation (amended and restated as of January 1, 2002) of
	ING Life Insurance and Annuity Company (formerly Aetna Life Insurance and Annuity
	Company) · Incorporated by reference to ING Life Insurance and Annuity Company
	annual report on Form 10-K (File No. 33-23376), as filed on March 28, 2002.
(6.2)	Amended and Restated By-Laws of ING Life Insurance and Annuity Company, effective
	January 1, 2005 · Incorporated by reference to the ILIAC 10-Q, as filed on May 13, 2005
	(File No. 033-23376, Accession No. 0001047469-05-014783).
(7)	Not applicable.
(8.1)	Fund Participation Agreement dated June 30, 1998 by and among AIM Variable
	Insurance Funds, Inc., A I M Distributors, Inc. and Aetna Life Insurance and Annuity
	Company · Incorporated by reference to Pre-Effective Amendment No. 1 to Registration
	Statement on Form N-4 (File No. 333-56297), as filed on August 4, 1998.
(8.2)	Amendment No. 1 dated October 1, 2000 to Participation Agreement dated June 30, 1998
	by and among AIM Variable Insurance Funds (formerly AIM Variable Insurance Funds,
	Inc.), AIM Distributors, Inc. and Aetna Life Insurance and Annuity Company ·
	Incorporated by reference to Post-Effective Amendment No. 24 to Registration Statement
	on Form N-4 (File No. 333-01107), as filed on April 13, 2001.
(8.3)	First Amendment dated November 17, 2000 to Participation Agreement dated June 30,
	1998 by and among AIM Variable Insurance Funds, (formerly AIM Variable Insurance
	Funds, Inc.), A I M Distributors, Inc. and Aetna Life Insurance and Annuity Company ·
	Incorporated by reference to Post-Effective Amendment No. 24 to Registration Statement
	on Form N-4 (File No. 333-01107), as filed on April 13, 2001.

(8.4)	Amendment dated July 12, 2002 to Participation Agreement dated as of June 30, 1998, as
	amended on October 1, 2000 and November 17, 2000 by and among AIM Variable
	Insurance Funds, A I M Distributors, Inc., Aetna Life Insurance Company and Annuity
	Company and Aetna Investment Services, LLC · Incorporated by reference to Post-
	Effective Amendment No. 32 to Registration Statement on Form N-4 (File No. 33-
	75988), as filed on April 13, 2004.
(8.5)	Service Agreement effective June 30, 1998 between Aetna Life Insurance and Annuity
	Company and AIM Advisors, Inc. · Incorporated by reference to Pre-Effective
	Amendment No. 1 to Registration Statement on Form N-4 (File No. 333-56297), as filed
	on August 4, 1998.
(8.6)	First Amendment dated October 1, 2000 to the Service Agreement dated June 30, 1998
	between Aetna Life Insurance and Annuity Company and AIM Advisors, Inc. ·
	Incorporated by reference to Pre-Effective Amendment No. 1 to Registration Statement
	on Form N-4 (File No. 333-49176), as filed on November 30, 2000.
(8.7)	Fund Participation Agreement dated March 1, 2000 between Aetna Life Insurance and
	Annuity Company and Alliance Capital · Incorporated by reference to Post-Effective
	Amendment No. 3 to Registration Statement on Form N-4 (File No. 333-87305), as filed
	on April 26, 2000.
(8.8)	Service Agreement dated March 1, 2000 between Aetna Life Insurance and Annuity
	Company and Alliance Capital · Incorporated by reference to Post-Effective Amendment
	No. 3 to Registration Statement on Form N-4 (File No. 333-87305), as filed on April 26,
	2000.
(8.9)	Fund Participation Agreement dated as of May 1, 1998 by and among Aetna Life
	Insurance and Annuity Company and Aetna Variable Fund, Aetna Variable Encore Fund,
	Aetna Income Shares, Aetna Balanced VP, Inc., Aetna GET Fund on behalf of each of its
	series, Aetna Generation Portfolios, Inc. on behalf of each of its series, Aetna Variable
	Portfolios, Inc. on behalf of each of its series, and Aeltus Investment Management, Inc. ·
	Incorporated by reference to Registration Statement on Form N-4 (File No. 333-56297),
	as filed on June 8, 1998.
(8.10)	Amendment dated November 9, 1998 to Fund Participation Agreement dated as of May
	1, 1998 by and among Aetna Life Insurance and Annuity Company and Aetna Variable
	Fund, Aetna Variable Encore Fund, Aetna Income Shares, Aetna Balanced VP, Inc.,
	Aetna GET Fund on behalf of each of its series, Aetna Generation Portfolios, Inc. on
	behalf of each of its series, Aetna Variable Portfolios, Inc. on behalf of each of its series,
	and Aeltus Investment Management, Inc. · Incorporated by reference to Post-Effective
	Amendment No. 2 to Registration Statement on Form N-4 (File No. 333-56297), as filed
	on December 14, 1998.
(8.11)	Second Amendment dated December 31, 1999 to Fund Participation Agreement dated as
	of May 1, 1998 and amended on November 9, 1998 by and among Aetna Life Insurance
	and Annuity Company and Aetna Variable Fund, Aetna Variable Encore Fund, Aetna
	Income Shares, Aetna Balanced VP, Inc., Aetna GET Fund on behalf of each of its series,
	Aetna Generation Portfolios, Inc. on behalf of each of its series, Aetna Variable
	Portfolios, Inc. on behalf of each of its series, and Aeltus Investment Management, Inc. ·
	Incorporated by reference to Post-Effective Amendment No. 19 to Registration Statement
	on Form N-4 (File No. 333-01107), as filed on February 16, 2000.

(8.12)	Third Amendment dated February 11, 2000 to Fund Participation Agreement dated as of
	May 1, 1998 and amended on November 9, 1998 and December 31, 1999 by and among
	Aetna Life Insurance and Annuity Company and Aetna Variable Fund, Aetna Variable
	Encore Fund, Aetna Income Shares, Aetna Balanced VP, Inc., Aetna GET Fund on
	behalf of each of its series, Aetna Generation Portfolios, Inc. on behalf of each of its
	series, Aetna Variable Portfolios, Inc. on behalf of each of its series, and Aeltus
	Investment Management, Inc. · Incorporated by reference to Post-Effective Amendment
	No. 20 to Registration Statement on Form N-4 (File No. 333-01107), as filed on April 4,
	2000.
(8.13)	Fourth Amendment dated May 1, 2000 to Fund Participation Agreement dated as of May
	1, 1998 and amended on November 9, 1998, December 31, 1999 and February 11, 2000
	by and among Aetna Life Insurance and Annuity Company and Aetna Variable Fund,
	Aetna Variable Encore Fund, Aetna Income Shares, Aetna Balanced VP, Inc., Aetna
	GET Fund on behalf of each of its series, Aetna Generation Portfolios, Inc. on behalf of
	each of its series, Aetna Variable Portfolios, Inc. on behalf of each of its series, and
	Aeltus Investment Management, Inc. · Incorporated by reference to Post-Effective
	Amendment No. 20 to Registration Statement on Form N-4 (File No. 333-01107), as
	filed on April 4, 2000.
(8.14)	Fifth Amendment dated February 27, 2001 to Fund Participation Agreement dated as of
	May 1, 1998 and amended on November 9, 1998, December 31, 1999, February 11, 2000
	and May 1, 2000 by and among Aetna Life Insurance and Annuity Company and Aetna
	Variable Fund, Aetna Variable Encore Fund, Aetna Income Shares, Aetna Balanced VP,
	Inc., Aetna GET Fund on behalf of each of its series, Aetna Generation Portfolios, Inc. on
	behalf of each of its series, Aetna Variable Portfolios, Inc. on behalf of each of its series,
	and Aeltus Investment Management, Inc. · Incorporated by reference to Post-Effective
	Amendment No. 24 to Registration Statement on Form N-4 (File No. 333-01107), as
	filed on April 13, 2001.
(8.15)	Sixth Amendment dated as of June 19, 2001 to Fund Participation Agreement dated as of
	May 1, 1998 and amended on November 9, 1998, December 31, 1999, February 11,
	2000, May 1, 2000 and February 27, 2001 among Aetna Life Insurance and Annuity
	Company, Aeltus Investment Management, Inc. and Aetna Variable Fund, Aetna
	Variable Encore Fund, Aetna Income Shares, Aetna Balanced VP, Inc., Aetna GET Fund,
	on behalf of each of its series, Aetna Generations Portfolios, Inc. on behalf of each of its
	series, and Aetna Variable Portfolios, Inc. on behalf of each of its series · Incorporated
	by reference to Post-Effective Amendment No. 32 to Registration Statement on Form N-
	4 (File No. 33-75988), as filed on April 13, 2004.
(8.16)	Service Agreement effective as of May 1, 1998 between Aeltus Investment Management,
	Inc. and Aetna Life Insurance and Annuity Company in connection with the sale of
	shares of Aetna Variable Fund, Aetna Variable Encore Fund, Aetna Income Shares,
	Aetna Balanced VP, Inc., Aetna GET Fund on behalf of each of its series, Aetna
	Generation Portfolios, Inc. on behalf of each of its series, and Aetna Variable Portfolios,
	Inc. on behalf of each of its series · Incorporated by reference to Registration Statement
	on Form N-4 (File No. 333-56297), as filed on June 8, 1998.

(8.17)	Amendment dated November 4, 1998 and effective as of October 15, 1998 to Service
	Agreement effective as of May 1, 1998 between Aeltus Investment Management, Inc.
	and Aetna Life Insurance and Annuity Company in connection with the sale of shares of
Aetna Variable Fund, Aetna Variable Encore Fund, Aetna Income Shares, Aetna
	Balanced VP, Inc., Aetna GET Fund on behalf of each of its series, Aetna Generation
	Portfolios, Inc. on behalf of each of its series, and Aetna Variable Portfolios, Inc. on
	behalf of each of its series · Incorporated by reference to Post-Effective Amendment No.
	2 to Registration Statement on Form N-4 (File No. 333-56297), as filed on December 14,
	1998.
(8.18)	Second Amendment dated February 11, 2000 to Service Agreement effective as of May
	1, 1998 and amended on November 4, 1998 between Aeltus Investment Management,
	Inc. and Aetna Life Insurance and Annuity Company in connection with the sale of
	shares of Aetna Variable Fund, Aetna Variable Encore Fund, Aetna Income Shares,
Aetna Balanced VP, Inc., Aetna GET Fund on behalf of each of its series, Aetna
	Generation Portfolios, Inc. on behalf of each of its series and Aetna Variable Portfolios,
Inc. on behalf of each of its series · Incorporated by reference to Post-Effective
	Amendment No. 20 to Registration Statement on Form N-4 (File No. 333-01107), as
	filed on April 4, 2000.
(8.19)	Third Amendment dated May 1, 2000 to Service Agreement effective as of May 1, 1998
	and amended on November 4, 1998 and February 11, 2000 between Aeltus Investment
	Management, Inc. and Aetna Life Insurance and Annuity Company in connection with
	the sale of shares of Aetna Variable Fund, Aetna Variable Encore Fund, Aetna Income
	Shares, Aetna Balanced VP, Inc., Aetna GET Fund on behalf of each of its series, Aetna
	Generation Portfolios, Inc. on behalf of each of its series and Aetna Variable Portfolios,
Inc. on behalf of each of its series · Incorporated by reference to Post-Effective
	Amendment No. 20 to Registration Statement on Form N-4 (File No. 333-01107), as
	filed on April 4, 2000.
(8.20)	Fourth Amendment dated as of June 26, 2001 to Service Agreement with Investment
	Advisor effective as of May 1, 1998, as amended on November 4, 1998, February 11,
	2000 and May 1, 2000 between Aeltus Investment Management, Inc. and Aetna Life
	Insurance and Annuity Company in connection with the sale of shares of Aetna Variable
	Fund, Aetna Variable Encore Fund, Aetna Income Shares, Aetna Balanced VP, Inc.,
	Aetna GET Fund on behalf of each of its series, Aetna Generation Portfolios, Inc. on
	behalf of each of its series and Aetna Variable Portfolios, Inc. on behalf of each of its
	series · Incorporated by reference to Post-Effective Amendment No. 32 to Registration
	Statement on Form N-4 (File No. 33-75988), as filed on April 13, 2004.
(8.21)	Fund Participation Agreement effective as of May 1, 1999 between Aetna Life Insurance
	and Annuity Company, Brinson Series Trust (formerly Mitchell Hutchins Series Trust),
	and Brinson Advisors, Inc. (formerly Mitchell Hutchins Asset Management, Inc.) ·
	Incorporated by reference to Post-Effective Amendment No. 8 to Registration Statement
	on Form N-4 (File No. 333-56297), as filed on June 25, 1999.
(8.22)	Service Agreement effective as of May 1, 1999 between Aetna Life Insurance and
Annuity Company and Brinson Advisors, Inc. (formerly Mitchell Hutchins Asset
	Management, Inc.) · Incorporated by reference to Post-Effective Amendment No. 8 to
	Registration Statement on Form N-4 (File No. 333-56297), as filed on June 25, 1999.

(8.23)	Fund Participation Agreement dated February 1, 1994 and amended on December 15,
	1994, February 1, 1995, May 1, 1995, January 1, 1996 and March 1, 1996 between Aetna
	Life Insurance and Annuity Company, Variable Insurance Products Fund and Fidelity
	Distributors Corporation · Incorporated by reference to Post-Effective Amendment No.
	12 to Registration Statement on Form N-4 (File No. 33-75964), as filed on February 11,
	1997.
(8.24)	Fifth Amendment dated as of May 1, 1997 to the Fund Participation Agreement dated
	February 1, 1994 and amended on December 15, 1994, February 1, 1995, May 1, 1995,
	January 1, 1996 and March 1, 1996 between Aetna Life Insurance and Annuity
	Company, Variable Insurance Products Fund and Fidelity Distributors Corporation ·
	Incorporated by reference to Post-Effective Amendment No. 30 to Registration Statement
	on Form N-4 (File No. 33-34370), as filed on September 29, 1997.
(8.25)	Sixth Amendment dated as of November 6, 1997 to the Fund Participation Agreement
	dated February 1, 1994 and amended on December 15, 1994, February 1, 1995, May 1,
	1995, January 1, 1996, March 1, 1996 and May 1, 1997 between Aetna Life Insurance
	and Annuity Company, Variable Insurance Products Fund and Fidelity Distributors
	Corporation · Incorporated by reference to Post-Effective Amendment No. 16 to
	Registration Statement on Form N-4 (File No. 33-75964), as filed on February 9, 1998.
(8.26)	Seventh Amendment dated as of May 1, 1998 to the Fund Participation Agreement dated
	February 1, 1994 and amended on December 15, 1994, February 1, 1995, May 1, 1995,
	January 1, 1996, March 1, 1996, May 1, 1997 and November 6, 1997 between Aetna Life
	Insurance and Annuity Company, Variable Insurance Products Fund and Fidelity
	Distributors Corporation · Incorporated by reference to Registration Statement on Form
	N-4 (File No. 333-56297), as filed on June 8, 1998.
(8.27)	Eighth Amendment dated December 1, 1999 to Fund Participation Agreement dated
	February 1, 1994 and amended on December 15, 1994, February 1, 1995, May 1, 1995,
	January 1, 1996, March 1, 1996, May 1, 1997, November 6, 1997 and May 1, 1998
	between Aetna Life Insurance and Annuity Company, Variable Insurance Products Fund
	and Fidelity Distributors Corporation · Incorporated by reference to Post-Effective
	Amendment No. 19 to Registration Statement on Form N-4 (File No. 333-01107), as
	filed on February 16, 2000.
(8.28)	Fund Participation Agreement dated February 1, 1994 and amended on December 15,
	1994, February 1, 1995, May 1, 1995, January 1, 1996 and March 1, 1996 between Aetna
	Life Insurance and Annuity Company, Variable Insurance Products Fund II and Fidelity
	Distributors Corporation · Incorporated by reference to Post-Effective Amendment No.
	12 to Registration Statement on Form N-4 (File No. 33-75964), as filed on February 11,
	1997.
(8.29)	Fifth Amendment dated as of May 1, 1997 to the Fund Participation Agreement dated
	February 1, 1994 and amended on December 15, 1994, February 1, 1995, May 1, 1995,
	January 1, 1996 and March 1, 1996 between Aetna Life Insurance and Annuity
	Company, Variable Insurance Products Fund II and Fidelity Distributors Corporation ·
	Incorporated by reference to Post-Effective Amendment No. 30 to Registration Statement
	on Form N-4 (File No. 33-34370), as filed on September 29, 1997.
(8.30)	Sixth Amendment dated as of January 20, 1998 to the Fund Participation Agreement
	dated February 1, 1994 and amended on December 15, 1994, February 1, 1995, May 1,
	1995, January 1, 1996, March 1, 1996 and May 1, 1997 between Aetna Life Insurance
	and Annuity Company, Variable Insurance Products Fund II and Fidelity Distributors
	Corporation · Incorporated by Reference to Post-Effective Amendment No. 7 to
	Registration Statement on Form S-6 (File No. 33-75248), as filed on February 24, 1998.

(8.31)	Seventh Amendment dated as of May 1, 1998 to the Fund Participation Agreement dated
	February 1, 1994 and amended on December 15, 1994, February 1, 1995, May 1, 1995,
	January 1, 1996, March 1, 1996, May 1, 1997 and January 20, 1998 between Aetna Life
	Insurance and Annuity Company, Variable Insurance Products Fund II and Fidelity
	Distributors Corporation · Incorporated by reference to Registration Statement on Form
	N-4 (File No. 333-56297), as filed on June 8, 1998.
(8.32)	Eighth Amendment dated December 1, 1999 to Fund Participation Agreement dated
	February 1, 1994 and amended on December 15, 1994, February 1, 1995, May 1, 1995,
	January 1, 1996, March 1, 1996, May 1, 1997, January 20, 1998 and May 1, 1998
	between Aetna Life Insurance and Annuity Company, Variable Insurance Products Fund
	II and Fidelity Distributors Corporation · Incorporated by reference to Post-Effective
	Amendment No. 19 to Registration Statement on Form N-4 (File No. 333-01107), as
	filed on February 16, 2000.
(8.33)	Letter Agreement dated May 16, 2007 and effective July 2, 2007 between ING Life
	Insurance and Annuity Company, Variable Insurance Products Fund, Variable Insurance
	Products Fund I, Variable Insurance Products Fund II, Variable Insurance Product Fund
	V and Fidelity Distributors Corporation · Incorporated by reference to Post-Effective
	Amendment No. 51 to the Registration Statement on Form N-4 (File No. 033-75962), as
	filed on July 27, 2007.
(8.34)	Service Agreement effective as of June 1, 2002 by and between Fidelity Investments
	Institutional Operations Company, Inc. and ING Financial Advisers, LLC · Incorporated
	by reference to Post-Effective Amendment No. 33 to Registration Statement on Form N-
	4 (File No. 33-75988), as filed on August 5, 2004.
(8.35)	Service Contract effective as of June 1, 2002 by and between Directed Services, Inc.,
	ING Financial Advisers, LLC, and Fidelity Distributors Corporation · Incorporated by
	reference to Post-Effective Amendment No. 33 to Registration Statement on Form N-4
	(File No. 33-75988), as filed on August 5, 2004.
(8.36)	Participation Agreement dated April 30, 2003 among ING Life Insurance and Annuity
	Company, The GCG Trust (renamed effective May 1, 2003, ING Investors Trust) and
	Directed Services, Inc. · Incorporated by reference to Post-Effective Amendment No. 54
	to Registration Statement on Form N-1A (File No. 33-23512), as filed on August 1, 2003.
(8.37)	Fund Participation Agreement made and entered into as of April 30, 1996, and amended
	on September 3, 1996, March 14, 1997 and November 28, 1997 by and among MFS
	Variable Insurance Trust, Aetna Life Insurance and Annuity Company and
	Massachusetts Financial Services Company · Incorporated by reference to Registration
	Statement on Form N-4 (File No. 333-56297), as filed on June 8, 1998.
(8.38)	Fourth Amendment dated May 1, 1998 to the Fund Participation Agreement dated April
	30, 1996, and amended on September 3, 1996, March 14, 1997 and November 28, 1997
	by and among MFS Variable Insurance Trust, Aetna Life Insurance and Annuity
	Company and Massachusetts Financial Services Company · Incorporated by reference to
	Pre-Effective Amendment No. 1 to Registration Statement on Form N-4 (File No. 333-
	56297), as filed on August 4, 1998.
(8.39)	Fifth Amendment dated May 1, 1998 to Fund Participation Agreement dated April 30,
	1996 and amended on September 3, 1996, March 14, 1997 and November 28, 1997 by
	and among MFS Variable Insurance Trust, Aetna Life Insurance and Annuity Company
	and Massachusetts Financial Services Company · Incorporated by reference to Post-
	Effective Amendment No. 4 to Registration Statement on Form N-4 (File No. 333-
	56297), as filed on February 16, 1999.

(8.40)	Fifth Amendment dated July 1, 1999 to Fund Participation Agreement dated April 30,
	1996 and amended on September 3, 1996, March 14, 1997, November 28, 1997 and May
	1, 1998 by and among MFS Variable Insurance Trust, Aetna Life Insurance and Annuity
	Company and Massachusetts Financial Services Company · Incorporated by reference to
	Post-Effective Amendment No. 11 to Registration Statement on Form N-4 (File No. 333-
	56297), as filed on November 23, 1999.
(8.41)	Sixth Amendment dated November 17, 2000 to the Fund Participation Agreement dated
	April 30, 1996 as amended on September 3, 1996, March 14, 1997, November 28, 1997,
	May 1, 1998 and July 1, 1999 by and among MFS Variable Insurance Trust, Aetna Life
	Insurance and Annuity Company, and Massachusetts Financial Services Company ·
	Incorporated by reference to Pre-Effective Amendment No. 1 to Registration Statement
	on Form N-4 (File No. 333-49176), as filed on November 30, 2000.
(8.42)	Fund Participation Agreement dated as of May 1, 2001 among Pilgrim Variable Products
	Trust, Aetna Life Insurance and Annuity Company and ING Pilgrim Securities, Inc. ·
	Incorporated by reference to Post-Effective Amendment No. 26 to Registration Statement
	on Form N-4 (File No. 333-01107), as filed on July 13, 2001.
(8.43)	Amendment dated August 30, 2002 between ING Life Insurance and Annuity Company,
	ING Variable Products Trust (formerly known as Pilgrim Variable Products Trust) and
	ING Funds Distributor to Fund Participation Agreement dated May 1, 2001 ·
	Incorporated by reference to Post-Effective Amendment No. 28 to Registration Statement
	on Form N-4 (File No. 33-75988), as filed on April 10, 2003.
(8.44)	Administrative and Shareholder Services Agreement dated April 1, 2001 between ING
	Funds Services, LLC and ING Life Insurance and Annuity Company (Administrator for
	ING Variable Products Trust) · Incorporated by reference to Post-Effective Amendment
	No. 28 to Registration Statement on Form N-4 (File No. 33-75988), as filed on April 10,
	2003.
(8.45)	Participation Agreement dated as of November 28, 2001 among Portfolio Partners, Inc.,
	Aetna Life Insurance and Annuity Company and Aetna Investment Services, LLC ·
	Incorporated by reference to Post-Effective Amendment No. 30 to Registration Statement
	on Form N-4 (File No. 33-75962), as filed on April 8, 2002.
(8.46)	Amendment dated March 5, 2002 between Portfolio Partners, Inc. (to be renamed ING
	Partners, Inc. effective May 1, 2002), Aetna Life Insurance and Annuity Company (to be
	renamed ING Life Insurance and Annuity Company effective May 1, 2002) and Aetna
	Investment Services LLC (to be renamed ING Financial Advisers, LLC) to Participation
	Agreement dated November 28, 2001 · Incorporated by reference to Post-Effective
	Amendment No. 30 to Registration Statement on Form N-4 (File No. 33-75962), as filed
	on April 8, 2002.
(8.47)	Amendment dated May 1, 2003 between ING Partners, Inc., ING Life Insurance and
	Annuity Company and ING Financial Advisers, LLC to the Participation Agreement
	dated as of November 28, 2001 and subsequently amended on March 5, 2002 ·
	Incorporated by reference to Post-Effective Amendment No. 28 to Registration Statement
	on Form N-4 (File No. 33-75988), as filed on April 10, 2003.
(8.48)	Amendment dated November 1, 2004 to the Participation Agreement between ING
	Partners, Inc., ING Life Insurance and Annuity Company and ING Financial Advisers,
	LLC dated as of November 28, 2001 and subsequently amended on March 5, 2002 and
	May 1, 2003 · Incorporated by reference to Post-Effective Amendment No. 20 to
	Registration Statement on Form N-1A (File No. 333-32575), as filed on April 1, 2005.

(8.49)	Amendment dated April 29, 2005 to the Participation Agreement between ING Partners,
	Inc., ING Life Insurance and Annuity Company and ING Financial Advisers, LLC dated
	as of November 28, 2001 and subsequently amended on March 5, 2002, May 1, 2003 and
	November 1, 2004 · Incorporated by reference to Post-Effective Amendment No. 32 to
	Registration Statement on Form N-4 (File No. 33-81216), as filed on April 11, 2006.
(8.50)	Amendment dated August 31, 2005 to the Participation Agreement between ING
	Partners, Inc., ING Life Insurance and Annuity Company and ING Financial Advisers,
	LLC dated November 28, 2001 and subsequently amended on March 5, 2002, May 1,
	2003, November 1, 2004 and April 29, 2005 · Incorporated by reference to Post-
	Effective Amendment No. 32 to Registration Statement on Form N-4 (File No. 33-
	81216), as filed on April 11, 2006.
(8.51)	Amendment dated December 7, 2005 to the Participation Agreement between ING
	Partners, Inc., ING Life Insurance and Annuity Company and ING Financial Advisers,
	LLC dated as of November 28, 2001 and subsequently amended on March 5, 2002, May
	1, 2003, November 1, 2004, April 29, 2005, and August 31, 2005 · Incorporated by
	reference to Post-Effective Amendment No. 32 to Registration Statement on Form N-4
	(File No. 33-81216), as filed on April 11, 2006.
(8.52)	Shareholder Servicing Agreement (Service Class Shares) dated as of November 27, 2001
	between Portfolio Partners, Inc. and Aetna Life Insurance and Annuity Company ·
	Incorporated by reference to Post-Effective Amendment No. 30 to Registration Statement
	on Form N-4 (File No. 33-75962), as filed on April 8, 2002.
(8.53)	Amendment dated March 5, 2002 between Portfolio Partners, Inc. (to be renamed ING
	Partners, Inc. effective May 1, 2002) and Aetna Life Insurance and Annuity Company (to
	be renamed ING Life Insurance and Annuity Company effective May 1, 2002) to the
	Shareholder Servicing Agreement dated November 27, 2001 · Incorporated by reference
	to Post-Effective Amendment No. 30 to Registration Statement on Form N-4 (File No.
	33-75962), as filed on April 8, 2002.
(8.54)	Amendment dated May 1, 2003 by and between ING Partners, Inc. and ING Life
	Insurance and Annuity Company to the Shareholder Servicing Agreement (Service Class
	Shares) dated November 27, 2001, as amended on March 5, 2002 · Incorporated by
	reference to Post-Effective Amendment No. 28 to Registration Statement on Form N-4
	(File No. 33-75988), as filed on April 10, 2003.
(8.55)	Form of Amendment dated November 1, 2004 to the Shareholder Servicing Agreement
	(Service Class Shares) by and between ING Partners, Inc. and ING Life Insurance and
	Annuity Company dated November 27, 2001, as amended on March 5, 2002 and May 1,
	2003 · Incorporated by reference to Post-Effective Amendment No. 33 to Registration
	Statement on Form N-4 (File No. 333-56297), as filed on April 17, 2006.
(8.56)	Amendment dated April 29, 2005 to the Shareholder Servicing Agreement (Service Class
	Shares) by and between ING Partners, Inc. and ING Life Insurance and Annuity
	Company dated November 27, 2001, and amended on March 5, 2002, May 1, 2003 and
	November 1, 2004 · Incorporated by reference to Post-Effective Amendment No. 32 to
	Registration Statement on Form N-4 (File No. 33-81216), as filed on April 11, 2006.
(8.57)	Form of Amendment dated December 7, 2005 to the Shareholder Servicing Agreement
	(Service Class Shares) by and between ING Partners, Inc. and ING Life Insurance and
	Annuity Company dated November 27, 2001, and amended on March 5, 2002, May 1,
	2003, November 1, 2004 and April 29, 2005 · Incorporated by reference to Post-
	Effective Amendment No. 33 to Registration Statement on Form N-4 (File No. 333-
	56297), as filed on April 17, 2006.
(9)	Opinion and Consent of Counsel, attached.
(10)	Consent of Independent Registered Public Accounting Firm, attached.

(11)	Not applicable.
(12)	Not applicable.
(13.1)	Powers of Attorney, Incorporated herein by reference to Post-effective Amendment 34 to
	a Registration Statement on Form N-4 for ING Life Insurance and Anuity Company
	Variable Annuity Account B filed with the Securities and Exchange Commission on
	April 20, 2007 (File Nos. 333-56297, 811-02512)
(13.2)	Authorization for Signatures · Incorporated by reference to Post-Effective Amendment
	No. 5 to Registration Statement on Form N-4 (File No. 33-75986), as filed on April 12,
	1996.

Item 25. Directors and Officers of the Depositor*

Name and Principal Business Address	Positions and Offices with Depositor
Thomas J. McInerney1	Director and Chairman
Kathleen A. Murphy1	Director
Catherine H. Smith1	Director and Senior Vice President
Robert W. Crispin3	Director
David A. Wheat2	Director, Executive Vice President and Chief Financial
Officer
Brian D. Comer1	President
Steven T. Pierson2	Senior Vice President and Chief Accounting Officer
Sue A. Collins1	Senior Vice President, Chief Actuary
Boyd G. Combs2	Senior Vice President, Tax
Shaun P. Mathews1	Senior Vice President
David S. Pendergrass2	Senior Vice President and Treasurer
Stephen J. Preston4	Senior Vice President
Harry N. Stout4	Senior Vice President
Valerie G. Brown2	Senior Vice President
Christopher Abreu1	Vice President and Actuary
Louis E Bachetti8	Vice President
Pamela Mulvey Barcia1	Vice President
Ronald R. Barhorst1	Vice President
Bradley E. Barks2	Vice President
Jeoffrey A. Block5	Vice President
Dianne C. Bogoian1	Vice President
Ira S. Braunstein2	Vice President, Investments
Mary A. Broesch4	Vice President and Actuary
Kevin P. Brown1	Vice President
Robert P. Browne2	Vice President, Investments
Anthony V. Camp, Jr.1	Vice President
Bruce Campbell1	Vice President and Actuary
Kevin L. Christensen5	Vice President
Nancy D. Clifford1	Vice President
Monte J. Combe6	Vice President
Dianne Clous1	Vice President
Patricia M. Corbett5	Vice President
Kimberly Curley6	Vice President and Actuary
Karen Czizik6	Vice President
Teri D. Deehan1	Vice President
J. Randolph Dobo6	Vice President
Michael C. Eldredge1	Vice President
Joseph Elmy2	Vice President, Tax
Patricia L. Engelhardt1	Vice President
William A. Evans1	Vice President
Ronald E. Falkner1	Vice President, Corporate Real Estate
Daniel J. Foley11	Vice President, Investments
John P. Foley2	Vice President, Investments
Stephen E. Gallant2	Vice President, Investments
Robert A. Garrey1	Vice President
Lisa S. Gilarde1	Vice President
Molly G. Garrett1	Vice President

Brian K. Haendiges1	Vice President
Steven J. Haun5	Vice President
June P. Howard2	Vice President
William S. Jasien7	Vice President
David A. Kelsey1	Vice President
Kenneth E. Lacy2	Vice President
William H. Leslie, IV1	Vice President
Richard K. Lau4	Vice President and Actuary
Frederick C. Litow2	Vice President
Laurie A. Lombardo1	Vice President
William L. Lowe1	Vice President
Alan S. Lurty4	Vice President
Christopher P. Lyons2	Vice President, Investments
Barbara L. March1	Vice President
Richard T. Mason12	Vice President
Gregory G. McGreevey2	Vice President, Investments
Gregory R. Michaud2	Vice President, Investments
Gregory J. Miller1	Vice President
Paul Mistretta2	Vice President
Maurice M. Moore2	Vice President, Investments
Brian J. Murphy1	Vice President
Michael J. Murphy4	Vice President
Todd E. Nevenhoven5	Vice President
Michael J. Pise1	Vice President
Deborah J. Prickett5	Vice President
Srinivas D. Reddy1	Vice President
Robert A. Richard1	Vice President
Linda E. Senker4	Vice President, Compliance
Frank W. Snodgrass13	Vice President
Libby J. Soong1	Vice President and Chief Compliance Officer
Carl Steinhilber1	Vice President
Sandra L. Stokley5	Vice President
Alice Su4	Vice President and Actuary
Lisa A. Thomas	Vice President and Appointed Actuary
Eugene M. Trovato1	Vice President
Mary A. Tuttle6	Vice President
William J. Wagner6	Vice President
Kurt W. Wassenar2	Vice President, Investments
Christopher R. Welp5	Vice President
Micki A. Wildin6	Vice President
Matthew L. Condos1	Actuary
Scott N. Shepherd1	Actuary
Joy M. Benner9	Secretary
Jane A. Boyle1	Assistant Secretary
Diana R. Cavender9	Assistant Secretary
Maria C. Foster9	Assistant Secretary
Linda H. Freitag2	Assistant Secretary
Daniel F. Hinkel2	Assistant Secretary
Joseph D. Horan2	Assistant Secretary
Megan A. Huddleston1	Assistant Secretary
Rita J. Kummer2	Assistant Secretary

Susan A. Masse1		Assistant Secretary
Terri W. Maxwell2		Assistant Secretary
James M. May, III2		Assistant Secretary
Randall K. Price9		Assistant Secretary
Patricia M. Smith1		Assistant Secretary
Edwina P. J. Steffer9		Assistant Secretary
John F. Todd1		Assistant Secretary
Susan M. Vega9		Assistant Secretary
Diane I. Yell10		Assistant Secretary
Glenn A. Black2		Tax Officer
Terry L. Owens2		Tax Officer
James H. Taylor2		Tax Officer
*	These individuals may also be directors and/or officers of other affiliates of the Company.

1	The principal business address of these directors and these officers is One Orange Way, Windsor,
	Connecticut 06095-4774.
2	The principal business address of these directors and these officers is 5780 Powers Ferry Road,
	N.W., Atlanta, Georgia 30327.
3	The principal business address of this director and this officer is 230 Park Avenue, New York, New
	York 10169.
4	The principal business address of these officers is 1475 Dunwoody Drive, West Chester,
	Pennsylvania 19380-1478.
5	The principal business address of these officers is 909 Locust Street, Des Moines, Iowa 50309.
6	The principal business address of these officers is 1290 Broadway, Denver, Colorado 80203.
7	The principal business address of this officer is 12701 Fair Lakes Circle, Suite 470, Fairfax, Virginia
	22033.
8	The principal business address of this officer is 5 Penn Plaza, 11th Floor, Lebanon, NY 10001.
9	The principal business address of these officers is 20 Washington Avenue South, Minneapolis,
	Minnesota 55401.
10	The principal business address of this officer is 100 Washington Square, Minneapolis, Minnesota
	55401.
11	The principal business address of this officer is 259 N. Radnor-Chester Road, Suite 205, Radnor,
	Pennsylvania 19087.
12	The principal business address of this officer is 440 S. Warren St., Suite 300/702, Syracuse NY
	13202
13	The principal business address of this officer is 9020 Overlook Boulevard, Brentwood, TN 37027

Item 26. Persons Controlled by or Under Common Control with the Depositor or Registrant

Incorporated herein by reference to Item 26 in Post Effective Amendment No. 6 to Registration Statement
on Form N-4 for ING USA Annuity and Life Insurance Company Separate Account EQ as filed with the
Securities and Exchange Commission on November 13, 2007 (File Nos. 333-111686, 811-08524).

Item 27. Number of Contract Owners

As of October 31, 2007, there were 23,188 individuals holding interests in variable annuity contracts
funded through Variable Annuity Account B of ING Life Insurance and Annuity Company.

Item 28. Indemnification

Section 33-779 of the Connecticut General Statutes (“CGS”) provides that a corporation may provide
indemnification of or advance expenses to a director, officer, employee or agent only as permitted by
Sections 33-770 to 33-778, inclusive, of the CGS. Reference is hereby made to Section 33-771(e) of the
CGS regarding indemnification of directors and Section 33-776(d) of CGS regarding indemnification of
officers, employees and agents of Connecticut corporations. These statutes provide in general that
Connecticut corporations incorporated prior to January 1, 1997 shall, except to the extent that their
certificate of incorporation expressly provides otherwise, indemnify their directors, officers, employees
and agents against “liability” (defined as the obligation to pay a judgment, settlement, penalty, fine,
including an excise tax assessed with respect to an employee benefit plan, or reasonable expenses
incurred with respect to a proceeding) when (1) a determination is made pursuant to Section 33-775 that
the party seeking indemnification has met the standard of conduct set forth in Section 33-771 or (2) a
court has determined that indemnification is appropriate pursuant to Section 33-774. Under Section 33-
775, the determination of and the authorization for indemnification are made (a) by two or more
disinterested directors, as defined in Section 33-770(3); (b) by special legal counsel; (c) by the
shareholders; or (d) in the case of indemnification of an officer, agent or employee of the corporation, by
the general counsel of the corporation or such other officer(s) as the board of directors may specify. Also,
Section 33-772 with Section 33-776 provide that a corporation shall indemnify an individual who was
wholly successful on the merits or otherwise against reasonable expenses incurred by him in connection
with a proceeding to which he was a party because he is or was a director, officer, employee, or agent of
the corporation. Pursuant to Section 33-771(d), in the case of a proceeding by or in the right of the
corporation or with respect to conduct for which the director, officer, agent or employee was adjudged
liable on the basis that he received a financial benefit to which he was not entitled, indemnification is
limited to reasonable expenses incurred in connection with the proceeding against the corporation to
which the individual was named a party.

Section 33-777 of the statute does specifically authorize a corporation to procure indemnification
insurance on behalf of an individual who was a director, officer, employee or agent of the corporation.
Consistent with the statute, ING Groep N.V. maintains an umbrella insurance policy with an international
insurer. The policy covers ING Groep N.V. and any company in which ING Groep N.V. has controlling
interest of 50% or more. This would encompass the principal underwriter as well as the depositor. The
policy provides for the following types of coverage: errors and omissions, directors and officers,
employment practices, fiduciary and fidelity.

Section 20 of the ING Financial Advisers, LLC Limited Liability Company Agreement executed as of
November 28, 2000 provides that ING Financial Advisers, LLC will indemnify certain persons against
any loss, damage, claim or expenses (including legal fees) incurred by such person if he is made a party
or is threatened to be made a party to a suit or proceeding because he was a member, officer, director,
employee or agent of ING Financial Advisers, LLC, as long as he acted in good faith on behalf of ING
Financial Advisers, LLC and in a manner reasonably believed to be within the scope of his authority. An
additional condition requires that no person shall be entitled to indemnity if his loss, damage, claim or
expense was incurred by reason of his gross negligence or willful misconduct. This indemnity provision
is authorized by and is consistent with Title 8, Section 145 of the General Corporation Law of the State of
Delaware.

Item 29. Principal Underwriter

(a) In addition to serving as the principal underwriter for the Registrant, ING Financial Advisers, LLC
also acts as the principal underwriter for ING Partners, Inc. (a management investment company
registered under the Investment Company Act of 1940 (1940 Act)). Additionally, ING Financial

Advisers, LLC acts as the principal underwriter for Variable Life Account B of ING Life Insurance
and Annuity Company (ILIAC), Variable Life Account C of ILIAC, Variable Annuity Account C
of ILIAC, Variable Annuity Account I of ILIAC and Variable Annuity Account G of ILIAC
(separate accounts of ILIAC registered as unit investment trusts under the 1940 Act). ING
Financial Advisers, LLC is also the principal underwriter for (i) Separate Account N of ReliaStar
Life Insurance Company (RLIC) (a separate account of RLIC registered as a unit investment trust
under the 1940 Act.), (ii) ReliaStar Select Variable Account of ReliaStar Life Insurance Company
(a separate account of RLIC registered as a unit investment trusts under the 1940 Act), (iii) MFS
ReliaStar Variable Account (a separate account of RLIC registered as a unit investment trusts under
the 1940 Act), (iv) Northstar Variable Account (a separate account of RLIC registered as a unit
investment trusts under the 1940 Act) (v) ReliaStar Life Insurance Company of New York Variable
Annuity Funds A, B, C (a management investment company registered under the 1940 Act), (vi)
ReliaStar Life Insurance Company of New York Variable Annuity Funds D, E, F, G, H, I (a
management investment company registered under the 1940 Act), (vii) ReliaStar Life Insurance
Company of New York Variable Annuity Funds M, P, and Q (a management investment company
registered under the1940 Act), and (viii) ReliaStar Life Insurance Company of New York Variable
Annuity Funds M P (a management investment company registered under the1940 Act).

(b) The following are the directors and officers of the Principal Underwriter:

Name and Principal Business Address	Positions and Offices with Principal Underwriter
Ronald R. Barhorst1	Director and President
Brian D. Comer1	Director and Senior Vice President
William L. Lowe1	Director and Senior Vice President
Kathleen A. Murphy1	Senior Vice President
Boyd G. Combs2	Senior Vice President, Tax
William Jasien3	Senior Vice President
Louis E. Bachetti5	Senior Vice President
Susan J. Stamm1	Chief Financial Officer
Pamela Mulvey Barcia1	Vice President
Robert H. Barley1	Vice President
M. Bishop Bastien6	Vice President
Dianne Clous Bogoian1	Vice President
J. Robert Bolchoz7	Vice President
David A. Brounley8	Vice President
Anthony V. Camp, Jr.1	Vice President
Mary Kathleen Carey-Reid1	Vice President
Virginia E. Carman1	Vice President
Nancy D. Clifford1	Vice President
William P. Elmslie9	Vice President
Joseph J. Elmy2	Vice President, Tax
Brian K. Haendiges1	Vice President
Bernard P. Heffernon10	Vice President
David Kelsey1	Vice President
Christina Lareau1	Vice President
George D. Lessner11	Vice President
Katherine E. Lewis12	Vice President
David J. Linney13	Vice President
Frederick C. Litow2	Vice President
Mark R. Luckinbill14	Vice President
Richard T. Mason15	Vice President

David Pendergrass2	Vice President and Treasurer
Ethel Pippin1	Vice President
Srinivas D. Reddy1	Vice President
Deborah Rubin16	Vice President
Todd Smiser17	Vice President
Frank W. Snodgrass18	Vice President
Christina M. Starks19	Vice President
Terran Titus1	Director, Vice President
S. Bradford Vaughan, Jr.20	Vice President
Forrest R. Wilson18	Vice President
Judeen T. Wrinn1	Vice President
Therese M. Squillacote1	Vice President and Chief Compliance Officer
Joy M. Benner4	Secretary
Diana R. Cavender4	Assistant Secretary
Randall K. Price4	Assistant Secretary
Edwina P. J. Steffer4	Assistant Secretary
John F. Todd1	Assistant Secretary
Glenn A. Black2	Tax Officer
Terry L. Owens2	Tax Officer
James H. Taylor2	Tax Officer

1	The principal business address of this director and these officers is One Orange Way, Windsor,
	Connecticut 06095-4774.
2	The principal business address of these officers is 5780 Powers Ferry Road, N.W., Atlanta, Georgia
	30327.
3	The principal business address of these officers is 12701 Fair Lakes Circle, Suite 470, Fairfax,
	Virginia 22033.
4	The principal business address of these officers is 20 Washington Avenue South, Minneapolis,
	Minnesota 55401.
5	The principal business address of these officers is 5 Penn Plaza, 11th Floor, Lebanon, NY 10001.
6	The principal business address of these officers is 980- Minth Street-ING, Sacramento, CA 95814.
7	The principal business address of these officers is South Carolina.
8	The principal business address of these officers is 45 Glastonbury Blvd., Glastonbury, CT 06033.
9	The principal business address of these officers is 230 Park Avenue, New York, NY 10169.
10	The principal business address of these officers is 10740 Nall Avenue, Suite 120, Overland Park, KS
	66211.
11	The principal business address of these officers is 15455 North Dallas Parkway, Addison, TX 75001.
12	The principal business address of these officers is 2675 N. Mayfair Road, Ste. 501, Milwaukee, WI
	53226.
13	The principal business address of these officers is 2900 N. Loop W., Ste. 180, Houston, TX 77092.
14	The principal business address of these officers is 2841 Plaza Place, Ste. 210, Raleigh, NC 27612.
15	The principal business address of these officers is 440 S. Warren St., Ste. 702, Syracuse, NY 13202.
16	The principal business address of these officers is 7701 Greenbelt Road, Greenbelt, MD 20770.
17	The principal business address of these officers is 2525 Cabot Drive, Ste. 100, Lisle, IL 60532.
18	The principal business address of these officers is 9020 Overlook Blvd., Brentwood, TN 37027.
19	The principal business address of these officers is 2000 21st Avenue NW, Minot, ND 58703.
20	The principal business address of these officers is 501 4th Avenue, Seattle, WA 98101.

(c) Compensation to Principal Underwriter during last fiscal year:
(1)	(2)	(3)	(4)	(5)
Name of	Net Underwriting	Compensation on
Principal	Discounts and	Redemption or	Brokerage
Underwriter	Commissions	Annuitization	Commissions	Compensation*
ING Financial				$2,507,216.09
Advisers, LLC

*	Reflects compensation paid to ING Financial Advisers, LLC attributable to regulatory and operating
	expenses associated with the distribution of all registered variable annuity products issued by
	Variable Annuity Account B of ING Life Insurance and Annuity Company during 2006.

Item 30. Location of Accounts and Records

All accounts, books and other documents required to be maintained by Section 31(a) of the 1940 Act and
the rules under it relating to the securities described in and issued under this Registration Statement are
maintained by ING Life Insurance and Annuity Company at One Orange Way, Windsor, Connecticut
06095-4774 and at ING Americas at 5780 Powers Ferry Road, Atlanta, Georgia 30327-4390 and at 1475
Dunwoody Drive, West Chester, Pennsylvania 19380-1478.

Item 31. Management Services

Not applicable.

Item 32. Undertakings

Registrant hereby undertakes:

(a)	to file a post-effective amendment to this registration statement on Form N-4 as frequently as is
	necessary to ensure that the audited financial statements in the registration statement are never
	more than sixteen months old for as long as payments under the variable annuity contracts may
	be accepted;
(b)	to include as part of any application to purchase a contract offered by a prospectus which is part
	of this registration statement on Form N-4, a space that an applicant can check to request a
	Statement of Additional Information; and
(c)	to deliver any Statement of Additional Information and any financial statements required to be
	made available under this Form N-4 promptly upon written or oral request.

The Company hereby represents that it is relying upon and complies with the provisions of Paragraphs (1)
through (4) of the SEC Staff’s No-Action Letter dated November 28, 1988 with respect to language
concerning withdrawal restrictions applicable to plans established pursuant to Section 403(b) of the
Internal Revenue Code. See American Counsel of Life Insurance; SEC No-Action Letter, [1988 WL
1235221 *13 (S.E.C.)]

Insofar as indemnification for liability arising under the Securities Act of 1933 may be permitted to
directors, officers and controlling persons of the Registrant pursuant to the foregoing provisions, or
otherwise, the Registrant has been advised that in the opinion of the Securities and Exchange Commission
such indemnification is against public policy as expressed in the Act and is, therefore, unenforceable. In

the event that a claim for indemnification against such liabilities (other than the payment by the Registrant
of expenses incurred or paid by a director, officer or controlling person of the Registrant in the successful
defense of any action, suit or proceeding) is asserted by such director, officer or controlling person in
connection with the securities being registered, the Registrant will, unless in the opinion of its counsel the
matter has been settled by controlling precedent, submit to a court of appropriate jurisdiction the question
of whether such indemnification by it is against public policy as expressed in the Act and will be
governed by the final adjudication of such issue.

ING Life Insurance and Annuity Company represents that the fees and charges deducted under the
contracts covered by this registration statement, in the aggregate, are reasonable in relation to the services
rendered, the expenses expected to be incurred, and the risks assumed by the insurance company.

SIGNATURES 

As required by the Securities Act of 1933, and the Investment Company Act of 1940, the Registrant, Variable
Annuity Account B of ING Life Insurance and Annuity Company, certifies that it meets the requirements of
Securities Act Rule 485(b) for effectiveness of this Post-Effective Amendment to its Registration Statement on
Form N-4 (File No. 333-56297) and has duly caused this Post-Effective Amendment to be signed on its behalf
by the undersigned, thereunto duly authorized, in the City of West Chester, Commonwealth of Pennsylvania, on
this 13^th day of November 2007.

VARIABLE ANNUITY ACCOUNT B OF
ING LIFE INSURANCE AND ANNUITY COMPANY
(Registrant)

By:	ING LIFE INSURANCE AND ANNUITY COMPANY
	(Depositor)
By:
	Brian D. Comer*
	President
By:	/s/ John S. Kreighbaum
	John S. (Scott) Kreighbaum
	Counsel of Depositor

Pursuant to the requirements of the Securities Act of 1933, this Post-Effective Amendment No. 35 to the
Registration Statement has been signed by the following persons in the capacities indicated on November
13, 2007.

Signatures	Officer Titles
	President
Brian D. Comer*	(Principal Executive Officer)
Thomas J. McInerney*	Director and Chairman
Kathleen A. Murphy*	Director
Catherine H. Smith*	Director and Senior Vice President
Robert W. Crispin*	Director
	Director, Executive Vice President and Chief
David A. Wheat*	Financial Officer
Steven T. Pierson*	Senior Vice President and Chief Accounting Officer

By:	/s/ John S. Kreighbaum
	John S. (Scott) Kreighbaum
Counsel of Depositor

*Executed by John S. (Scott) Kreighbaum on behalf of those indicated pursuant to Powers of Attorney.

VARIABLE ANNUITY ACCOUNT B
EXHIBIT INDEX
ITEM	EXHIBIT	PAGE #
(9)	Opinion and Consent of Counsel	EX-99.B9
(10)	Consent of Independent Registered Public Accounting Firm	EX-99.B10

EX-99.B9

[ING STATIONERY]

November 13, 2007

Members of the Board of Directors
ING Life Insurance and Annuity Company
1475 Dunwoody Drive
West Chester, PA 19380-1478

Ladies and Gentlemen:

In my capacity as Counsel for (the “Company”), I have examined the Registration Statement on Form N-4
in connection with the registration under the Securities Act of 1933, as amended to the date hereof, of an
indefinite number of units of interest in Variable Annuity Account B of the Company (the “Account”). I
am familiar with the proceedings taken and proposed to be taken in connection with the authorization,
issuance and sale of units.

Based upon my examination and upon my knowledge of the corporate activities relating to the Account, it
is my opinion that:

(1)	The Company was organized in accordance with the laws of the State of Connecticut and is
	a duly authorized stock life insurance company under the laws of Connecticut and the laws
	of those states in which the Company is admitted to do business;
(2)	The Account is a validly established separate investment account of the Company;
(3)	Under Connecticut law, the portion of the assets to be held in the Account equals the
	reserve and other liabilities for variable benefits under variable annuity contracts to be
	issued by the Account, and such assets are not chargeable with liabilities arising out of any
	other business the Company conducts;
(4)	The units and the variable annuity contracts will, when issued and sold in the manner
	described in the registration statement, be legal and binding obligations of the Company
	and will be legally and validly issued, fully paid, and non-assessable.

I hereby consent to the filing of this opinion as an exhibit to the registration statement.

Sincerely,

/s/ John S. Kreighbaum
John S. (Scott) Kreighbaum
Counsel

1475 Dunwoody Drive
West Chester, PA 19380
Tel: (610) 425-3404
Fax: (610) 425-3520

EX-99.B10

Exhibit 99-B.10 – Consent of Ernst and Young LLP, Independent Registered Public
Accounting Firm

We consent to the reference to our firm under the caption “Independent Registered Public
Accounting Firm” and to the use of our report dated March 23, 2007, with respect to the
consolidated financial statements of ING Life Insurance and Annuity Company as of
December 31, 2006 and 2005 and for each of the three years in the period ended
December 31, 2006, and to the use of our report dated March 23, 2007, with respect to
the statements of assets and liabilities of Variable Annuity Account B of ING Life
Insurance and Annuity Company as of December 31, 2006, and the related statements of
operations and changes in net assets for the periods disclosed in the financial statements,
incorporated by reference in Post-Effective Amendment No. 35 to the Registration
Statement (Form N-4 No. 333-56297) and the related Prospectus and Statement of
Additional Information of Variable Annuity Account B of ING Life Insurance and
Annuity Company.

/s/ Ernst & Young LLP 

Atlanta, Georgia
November 12, 2007