485BPOS 1 final.htm REGISTRATION STATEMENT final.htm - Generated by SEC Publisher for SEC Filing
As filed with the Securities and Exchange  Registration No. 33-34370* 
Commission on June 24, 2009  Registration No. 811-02512 

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION 
Washington, D.C. 20549
 
FORM N-4
 
Post-Effective Amendment No. 62
REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 
and
Amendment to

REGISTRATION STATEMENT UNDER THE INVESTMENT COMPANY ACT OF 1940

Variable Annuity Account B
(Exact Name of Registrant)
of
 
ING LIFE INSURANCE AND ANNUITY COMPANY 
(Name of Depositor)
 
One Orange Way
Windsor, Connecticut 06095-4774
(860) 580-4646
(Address and Telephone Number of Depositor’s Principal Office) 

John S. (Scott) Kreighbaum, Esq.  Copy to: 
ING Americas (U.S. Legal Services)  J. Neil McMurdie, Counsel 
1475 Dunwoody Drive, West Chester, PA 19380-1478  ING Americas (U.S. Legal Services) 
(610) 425-3404  One Orange Way, C1S, Windsor, CT, 06095-4774 
(Name and Address of Agent for Service of Process)   

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 (check appropriate box): 
[ X ]  immediately upon filing pursuant to paragraph (b) of Rule 485 
[ ]  on [ ], 2009, pursuant to paragraph (b) of Rule 485 
[ ]  60 days after filing pursuant to paragraph (a)(1) 
[ ]  on ____________, pursuant to paragraph (a)(1) 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


*      Pursuant to Rule 429(a) under the Securities Act of 1933, Registrant has included a combined prospectus under this Registration Statement which includes all the information which would currently be required in a prospectus relating to the following earlier Registration Statement: 33-87932.

PARTS A and B

EXPLANATORY NOTE: Each of the Prospectus and Statement of Additional Information, dated May 1, 2009 and as supplemented, is incorporated into Parts A and B, respectively, of this amendment by reference to Post-Effective Amendment No. 61 to this Registration Statement, as filed on April 29, 2009 (Accession No. 0000897899-09-000027). 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 June 24, 2009
To The Prospectuses Dated May 1, 2009 For 
 
ING Income Annuity
ING Variable Annuity
ING Marathon Plus
 
Issued By ING Life Insurance and Annuity Company 
Through Its Variable Annuity Account B

This supplement updates the 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 Service Center at 1-800-366-0066.

The following additional investment portfolio will be available under your Contract – effective July 20, 2009, with more information about it hereby added to the “Description of Underlying Funds” in the Appendix (and its name hereby added to the list of available investment portfolios toward the front of the prospectus).

Fund Name  Investment Adviser/  Investment Objective 
  Subadviser   
ING Variable Portfolios, Inc.     
   ING Russell™ Large Cap Growth Index  Investment Adviser: ING  Seeks investment results (before fees 
   Portfolio (Class I)  Investments, LLC  and expenses) that correspond to the 
  Investment Subadviser: ING  total return of the Russell Top 200® 
  Investment Management Co.  Growth Index. 

ILIAC - 154073

06/2009


PART C - OTHER INFORMATION

Item 24.  Financial Statements and Exhibits 
  (a)  Financial Statements: 
    (1)  Incorporated in Part A 
      Condensed Financial Information 
    (2)  Incorporated in Part B: 
      Financial Statements of Variable Annuity Account B: 
           -  Report of Independent Registered Public Accounting Firm 
           -  Statements of Assets and Liabilities as of December 31, 2008 
           -  Statements of Operations for the year ended December 31, 2008 
           -  Statements of Changes in Net Assets for the years ended December 31, 2008 and 
        2007 
           -  Notes to Financial Statements 
                   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, 2008, 
        2007 and 2006 
           -  Consolidated Balance Sheets as of December 31, 2008 and 2007 
           -  Consolidated Statements of Changes in Shareholder’s Equity for the years ended 
        December 31, 2008, 2007 and 2006 
           -  Consolidated Statements of Cash Flows for the years ended December 31, 2008, 
        2007 and 2006 
           -  Notes to Financial Statements 
  (b)  Exhibits   
    (1)  Resolution establishing Variable Annuity Account B (“Registrant”). (Incorporated by 
      reference to Post-Effective Amendment No. 6 to the 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 herein by reference to Post- 
      Effective Amendment No. 32 to Registration Statement on Form N-4, File No. 33- 
      81216, as filed on April 22, 1996.) 
    (3.2)  Underwriting Agreement dated November 17, 2006, between ING Life Insurance and 
      Annuity Company and ING Financial Advisers, LLC. (Incorporated herein by reference 
      to Post-Effective Amendment No. 34 to Registration Statement on Form N-4, File No. 
       33-75996, as filed on December 20, 2006.) 
    (3.3)  Confirmation of Underwriting Agreement. (Incorporated herein 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)  Federated Broker Dealer Agreement (9/2/94). (Incorporated herein by reference to Post- 
      Effective Amendment No. 3 to Registration Statement on Form N-4, File No. 33-79122, 
      as filed on August 16, 1995.) 
    (3.5)  Form of Rule 22c-2 Agreement. (Incorporated herein by reference to Post-Effective 
      Amendment No. 10 to Registration Statement on Form N-4, File No. 333-115515, as 
      filed on April 12, 2007.) 
    (4.1)  Variable Annuity Contract (G-CDA-97(NY)). (Incorporated herein by reference to Post- 
      Effective Amendment No. 32 to Registration Statement on Form N-4, File No. 33- 
      34370, as filed on December 16, 1997.) 
    (4.2)  Variable Annuity Contract Certificate (GMCCC-97(NY)) to Contract G-CDA-97(NY). 
      (Incorporated herein by reference to Post-effective Amendment 32 to Registration 
      Statement on Form N-4, File No. 33-34370, as filed on December 16, 1997.) 
    (4.3)  Variable Annuity Contract (G-MP1(5/97)). (Incorporated herein 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.) 


(4.4)  Variable Annuity Contract Certificate (MP1CERT(5/97)). (Incorporated herein 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.) 
(4.5)  Variable Annuity Contract (I-MP1(5/97)). (Incorporated herein 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.) 
(4.6)  Variable Annuity Contract (G-MP1(5/96)). (Incorporated herein by reference to Post- 
  Effective Amendment No. 26 to Registration Statement on Form N-4, File No. 33- 
  34370, as filed on February 21, 1997.) 
(4.7)  Variable Annuity Contract Certificate (MP1CERT(5/96)). (Incorporated herein by 
  reference to Post-Effective Amendment No. 26 to Registration Statement on Form N-4, 
  File No. 33-34370, as filed on February 21, 1997.) 
(4.8)  Variable Annuity Contract (G-CDA-96(NY)). (Incorporated herein by reference to Post- 
  Effective Amendment No. 26 to Registration Statement on Form N-4, File No. 33- 
  34370, as filed on February 21, 1997.) 
(4.9)  Variable Annuity Contract (I-MP1(5/96)). (Incorporated herein by reference to Post- 
  Effective Amendment No. 26 to Registration Statement on Form N-4, File No. 33- 
  34370, as filed on February 21, 1997.) 
(4.10)  Variable Annuity Contract Certificate (GMCC-96(NY)). (Incorporated herein by 
  reference to Post-Effective Amendment No. 26 to Registration Statement on Form N-4, 
  File No. 33-34370, as filed on February 21, 1997.) 
(4.11)  Variable Annuity Contract (G-CDA-IC(NQ)). (Incorporated herein by reference to Post- 
  Effective Amendment No. 35 to Registration Statement on Form N-4, File No. 33- 
  34370, as filed on April 17, 1998.) 
(4.12)  Variable Annuity Contract Certificate (GMCC-IC(NQ)). (Incorporated herein by 
  reference to Post-Effective Amendment No. 35 to Registration Statement on Form N-4, 
  File No. 33-34370, as filed on April 17, 1998.) 
(4.13)  Variable Annuity Contract Certificate (GMCC-IC(NQ/MP)). (Incorporated herein by 
  reference to Post-Effective Amendment No. 35 to Registration Statement on Form N-4, 
  File No. 33-34370, as filed on April 17, 1998.) 
(4.14)  Variable Annuity Contract (G-CDA-IC(IR)). (Incorporated herein by reference to Post- 
  Effective Amendment No. 35 to Registration Statement on Form N-4, File No. 33- 
  34370, as filed on April 17, 1998.) 
(4.15)  Variable Annuity Contract Certificate (GMCC-IC(IR)). (Incorporated herein by 
  reference to Post-Effective Amendment No. 37 to Registration Statement on Form N-4, 
  File No. 33-34370, as filed on April 9, 1999.) 
(4.16)  Variable Annuity Contract (I-CDA-IC(IR/MP)). (Incorporated herein by reference to 
  Post-Effective Amendment No. 35 to Registration Statement on Form N-4, File No. 33- 
  34370, as filed on April 17, 1998.) 
(4.17)  Variable Annuity Contracts and Certificates (G-CDA-IC(IR/NY)), (GMCC-IC(IR/NY)), 
  (G-CDA-IC(NQ/NY)) and (GMCC-IC(NQ/NY)). (Incorporated herein by reference to 
  Post-Effective Amendment No. 1 to Registration Statement on Form N-4, File No. 33- 
  87932), as filed on September 19, 1995.) 
(4.18)  Endorsements (MP1IRA(5/97)) and (I-MP1IRA(5/97)) to Contract G-MP1(5/96) and 
  Certificate MP1CERT(5/96). (Incorporated herein by reference to Post-Effective 
  Amendment No. 26 to Registration Statement on Form N-4, File No. 33-34370, as filed 
  on February 21, 1997.) 
(4.19)  Endorsements (MP1QP(5/97)) and (I-MP1QP(5/97)) to Contract G-MP1(5/96) and 
  Certificate MP1CERT(5/96). (Incorporated herein by reference to Post-Effective 
  Amendment No. 26 to Registration Statement on Form N-4, File No. 33-34370, as filed 
  on February 21, 1997.) 
(4.20)  Endorsements (MP1TDA(5/97)) and (I-MP1TDA(5/97)) to Contract G-MP1(5/96) and 
  Certificate MP1CERT(5/96). (Incorporated herein by reference to Post-Effective 
  Amendment No. 26 to Registration Statement on Form N-4, File No. 33-34370, as filed 
  on February 21, 1997.) 


(4.21)  Endorsements (MP1DC(5/97)) and (I-MP1DC(5/97)) to Contract G-MP1(5/96) and 
  Certificate MP1CERT(5/96). (Incorporated herein by reference to Post-Effective 
  Amendment No. 26 to Registration Statement on Form N-4, File No. 33-34370, as filed 
  on February 21, 1997.) 
(4.22)  Endorsement (MP1IRA(11/96)) to Contract G-CDA-96(NY) and Certificate GMCC- 
  96(NY). (Incorporated herein by reference to Post-Effective Amendment No. 26 to 
  Registration Statement on Form N-4, File No. 33-34370, as filed on February 21, 1997.) 
(4.23)  Endorsement (MP1END(9/97)) to Contract I-MP1(5/97). (Incorporated herein 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.) 
(4.24)  Endorsement (E1-MPROTH-97)) to Contract G-MP1(5/97). (Incorporated herein by 
  reference to Post-Effective Amendment No. 32 to Registration Statement on Form N-4, 
  File No. 33-34370, as filed on December 16, 1997.) 
(4.25)  Endorsement (EI1MPROTH-97)) to Contract IMP1(5/97). (Incorporated herein by 
  reference to Post-Effective Amendment No. 32 to Registration Statement on Form N-4, 
  File No. 33-34370, as filed on December 16, 1997.) 
(4.26)  Endorsement (MP1IRA(11/97) to Contract G-MP1(5/97)). (Incorporated herein by 
  reference to Post-Effective Amendment No. 32 to Registration Statement on Form N-4, 
  File No. 33-34370, as filed on December 16, 1997.) 
(4.27)  Endorsement (I-MP1IRA(11/97) to Contract I-MP1(5/97)). (Incorporated herein by 
  reference to Post-Effective Amendment No. 32 to Registration Statement on Form N-4, 
  File No. 33-34370, as filed on December 16, 1997.) 
(4.28)  Endorsement (MP1END(9/97)) to Contract G-MP1(5/97) and Certificate 
  MP1CERT(5/97). (Incorporated herein by reference to Post-Effective Amendment No. 
  33 to Registration Statement on Form N-4, File No. 33-34370, as filed on February 12, 
  1998.) 
(4.29)  Endorsement (I-MP1END(9/97)) to Contract I-MP1(5/97). (Incorporated herein by 
  reference to Post-Effective Amendment No. 33 to Registration Statement on Form N-4, 
  File No. 33-34370, as filed on February 12, 1998.) 
(4.30)  Endorsement (MPNQEND(4/95) to Contract G-CDA-IC(NQ). (Incorporated herein by 
  reference to Post-Effective Amendment No. 34 to Registration Statement on Form N-4, 
  File No. 33-34370, as filed on February 27, 1998.) 
(4.31)  Endorsement (MPIREND(4/95) to Contract G-CDA-IC(IR). (Incorporated herein by 
  reference to Post-Effective Amendment No. 34 to Registration Statement on Form N-4, 
  File No. 33-34370, as filed on February 27, 1998.) 
(4.32)  Endorsement (IMPNQEND(4/95) to Contract I-CDA-IC(NQ/MP). (Incorporated herein 
  by reference to Post-Effective Amendment No. 34 to Registration Statement on Form N- 
  4, File No. 33-34370, as filed on February 27, 1998.) 
(4.33)  Endorsement (EMPGET98) to Contract G-MP1(5/97). (Incorporated herein by reference 
  to Post-Effective Amendment No. 37 to Registration Statement on Form N-4, File No. 
  33-34370, as filed on September 14, 1998.) 
(4.34)  Endorsement (MPNQCERTEND(4/95)) to Certificate GMCC-IC(NQ). (Incorporated 
  herein by reference to Post-Effective Amendment No. 34 to Registration Statement on 
  Form N-4, File No. 33-34370, as filed on February 27, 1998.) 
(4.35)  Endorsement (MPIRCERTEND(4/95)) to Certificate GMCC-IC(IR). (Incorporated 
  herein by reference to Post-Effective Amendment No. 34 to Registration Statement on 
  Form N-4, File No. 33-34370, as filed on February 27, 1998.) 
(4.36)  Endorsement (EGET(99) to Contracts (Incorporated herein 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.) 
(4.37)  Endorsement ENMCHG(05/02) and ENMCHG1(05/02) for name change. (Incorporated 
  herein 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.) 
(4.38)  Contract Schedule I Accumulation Period (G-MP1(11/97)-5) to Group Contract G- 
  MP1(5/97). (Incorporated herein by reference to post-Effective Amendment No. 32 to 
  Registration Statement on Form N-4, File No. 333-34370, as filed on April 8, 2002.) 


(4.39)  Contract Schedule I Accumulation Period (I-MP1(11/97)-5) to Individual Contract I- 
  MP1(5/97). (Incorporated herein by reference to post-Effective Amendment No. 32 to 
  Registration Statement on Form N-4, File No. 333-34370, as filed on April 8, 2002.) 
(5.1)  Variable Annuity Contract Application (MPAPPNY(1/96). (Incorporated herein by 
  reference to Post-Effective Amendment No. 32 to Registration Statement on Form N-4, 
  File No. 33-34370, as filed on December 16, 1997.) 
(5.2)  Variable Annuity Contract Application (300-MAR-IB). (Incorporated herein by 
  reference to Post-Effective Amendment No. 29 to Registration Statement on Form N-4, 
  File No. 33-34370, as filed on August 18, 1997.) 
(5.3)  Variable Annuity Contract Application (710.6.13). (Incorporated herein by reference to 
  Post-Effective Amendment No. 29 to Registration Statement on Form N-4, File No. 33- 
  34370, as filed on August 18, 1997.) 
(6.1)  Restated Certificate of Incorporation (amended and restated as of October 1, 2007) of 
  ING Life Insurance and Annuity Company). (Incorporated herein by reference to ING 
  Life Insurance and Annuity Company Annual Report on Form 10-K, File No. 33-23376, 
  as filed on March 31, 2008.) 
(6.2)  Amended and Restated By-Laws of ING Life Insurance and Annuity Company, 
  effective October 1, 2007. (Incorporated herein by reference to the ING Life Insurance 
  and Annuity Company annual report on form 10-K, File No. 33-23376, as filed on 
  March 31, 2008.) 
(7)  Not Applicable 
(8.1)  Amended and Restated Fund Participation Agreement dated as of March 31, 1995, 
  between Aetna Life Insurance and Annuity Company, Alger American Fund and Fred 
  Alger Management, Inc. (Incorporated herein 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.) 
(8.2)  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 it series, and Aeltus Investment 
  Management, Inc. (Incorporated herein by reference to Initial Registration Statement on 
  Form N-4, File No. 333-56297, as filed on June 8, 1998.) 
(8.3)  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 it series, 
  and Aeltus Investment Management, Inc. (Incorporated herein by reference to Post- 
  Effective Amendment No. 2 on Form N-4, File No. 333-56297, as filed on December 
  14, 1998.) 
(8.4)  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 it series, and Aeltus Investment 
  Management, Inc. (Incorporated herein by reference to Post-Effective Amendment No. 
  19 on Form N-4, File No. 333-01107, as filed on February 16, 2000.) 


(8.5)  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 it series, and Aeltus 
  Investment Management, Inc. (Incorporated herein by reference to Post-Effective 
  Amendment No. 20 on Form N-4, File No. 333-01107, as filed on April 4, 2000.) 
(8.6)  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 it series, 
  and Aeltus Investment Management, Inc. (Incorporated herein by reference to Post- 
  Effective Amendment No. 20 on Form N-4, File No. 333-01107, as filed on April 4, 
  2000.) 
(8.7)  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 it series, and Aeltus Investment Management, Inc. (Incorporated herein by 
  reference to Post-Effective Amendment No. 24 on Form N-4, File No. 333-01107, as 
  filed on April 13, 2001.) 
(8.8)  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, 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 it series, and Aeltus Investment Management, Inc. 
  (Incorporated herein by reference to Post-Effective Amendment No. 32 on Form N-4, 
  File No. 33-75988, as filed on April 13, 2004.) 
(8.9)  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 herein by reference to Initial 
  Registration Statement on Form N-4, File No. 333-56297, as filed on June 8, 1998.) 
(8.10)  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 herein 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 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 herein 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.) 
(8.12)  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 herein 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 as of June 26, 2001, to Service Agreement effective as of May 
  1, 1998, and 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 
  herein 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.) 
(8.14)  Fund Participation Agreement dated December 1, 1997, among Calvert Responsibly 
  Invested Balanced Portfolio, Calvert Asset Management Company, Inc. and Aetna Life 
  Insurance and Annuity Company. (Incorporated herein by reference to Post-Effective 
  Amendment No. 8 to Registration Statement on Form N-4, File No. 333-01107, as filed 
  on February 19, 1998.) 
(8.15)  Service Agreement dated December 1, 1997, between Calvert Asset Management Asset 
  Management Company, Inc. and Aetna Life Insurance and Annuity Company. 
  (Incorporated herein by reference to Post-Effective Amendment No. 8 to Registration 
  Statement on Form N-4, File No. 333-01107, as filed on February 19, 1998.) 
(8.16)  Rule 22c-2 Agreement dated no later than April 16, 2007, and is effective as of October 
  16, 2007, between Calvert Distributors, Inc., ING Life Insurance and Annuity Company, 
  ING National Trust, ING USA Annuity and Life Insurance Company, ReliaStar Life 
  Insurance Company, ReliaStar Life Insurance Company of New York, Security Life of 
  Denver Insurance Company and Systematized Benefits Administrators, Inc. 
  (Incorporated herein by reference to Post-Effective Amendment No. 60 to Registration 
  Statement on form N-4, File No. 33-75962, as filed on June 15, 2007.) 
(8.17)  Fund Participation Agreement dated July 1, 1994, by and among Aetna Life Insurance 
  and Annuity Company, Insurance Management Series and Federated Advisors. 
  (Incorporated herein by reference to Post-Effective Amendment No. 8 to Registration 
  Statement on Form N-4, File No. 33-34370, as filed on April 16, 1997.) 
(8.18)  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 herein 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.) 


(8.19)  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 herein 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.) 
(8.20)  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 herein by reference to Post-Effective Amendment No. 7 to 
  Registration Statement on Form S-6, File No. 33-75248, as filed on February 9, 1998.) 
(8.21)  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 herein by reference to Initial 
  Registration on Form N-4, File No. 333-56297, as filed on June 8, 1998.) 
(8.22)  Eighth Amendment dated as of December 1, 1999, 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, November 6, 1997, and May 1, 
  1998, between Aetna Life Insurance and Annuity Company, Variable Insurance 
  Products Fund and Fidelity Distributors Corporation. (Incorporated herein 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.) 
(8.23)  Ninth Amendment dated as of August 15, 2007, 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, November 6, 1997, May 1, 1998, 
  and December 1, 1999, between Aetna Life Insurance and Annuity Company, Variable 
  Insurance Products Fund and Fidelity Distributors Corporation. (Incorporated herein by 
  reference to Post-Effective Amendment No. 46 to Registration Statement on Form N-4, 
  File No. 333-01107, as filed on February 15, 2008.) 
(8.24)  Rule 22c-2 Agreement dated no later than April 16, 2007, and is effective as of October 
  16, 2007, between Fidelity Distributors Corporation, ING Life Insurance and Annuity 
  Company, ING National Trust, ING USA Annuity and Life Insurance Company, 
  ReliaStar Life Insurance Company, ReliaStar Life Insurance Company of New York, 
  Security Life of Denver Insurance Company and Systematized Benefits Administrators, 
  Inc. (Incorporated herein by reference to Post-Effective Amendment No. 50 to 
  Registration Statement on Form N-4, File No. 33-75962, as filed on June 15, 2007. 
(8.25)  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 herein 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.) 
(8.26)  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 herein 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.) 


(8.27)  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 herein by reference to Post-Effective Amendment No. 7 to 
  Registration Statement on Form N-4, File No. 33-75248, as filed on February 24, 1998.) 
(8.28)  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, May 1, 1997 and January 20, 1998, 
  between Aetna Life Insurance and Annuity Company, Variable Insurance Products Fund 
  II and Fidelity Distributors Corporation. (Incorporated herein by reference to Initial 
  Registration Statement on Form N-4, File No. 33-75248, as filed on June 8, 1998.) 
(8.29)  Eighth Amendment dated as of December 1, 1999, 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, 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 herein 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.) 
(8.30)  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 Products Fund 
  V and Fidelity Distributors Corporation. (Incorporated herein by reference to Post- 
  Effective Amendment No. 51 to the Registration Statement on Form N-4, File No. 33- 
  75962, a filed on July 27, 2007.) 
(8.31)  Service Agreement effective as of June 1, 2002, by and between Directed Services, Inc., 
  ING Financial Advisers, LLC, and Fidelity Distributors Corporation. (Incorporated 
  herein 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.) 
(8.32)  Service Contract effective as of June 1, 2002, by and between Directed Services, Inc., 
  ING Financial Advisers, LLC, and Fidelity Distributors Corporation. (Incorporated 
  herein 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.) 
(8.33)  Fund 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 herein 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.) 
(8.34)  Fund Participation Agreement dated December 1, 1988, and amended February 11, 
  1991, between Aetna Life Insurance and Annuity Company and Lexington Management 
  Corporation regarding Natural Resources Trust. (Incorporated herein 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.) 
(8.35)  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 Company. (Incorporated herein by reference to Initial Registration 
  Statement on Form N-4, File No. 333-56297, as filed on June 8, 1998.) 
(8.37)  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 Company. (Incorporated herein 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.) 


(8.38)  Fifth Amendment dated May 1, 1998, to the 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 Company. (Incorporated herein 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.) 
(8.39)  Fifth Amendment dated July 1, 1999, to the 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 Company. (Incorporated herein by reference 
  to Post-Effective Amendment No. 4 to Registration Statement on Form N-4, File No. 
  333-56297, as filed on November 23, 1999.) 
(8.40)  Sixth Amendment dated November 17, 2000, to the Fund Participation Agreement dated 
  April 30, 1996, and 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 Company. 
  (Incorporated herein by reference to Post-Effective Amendment No. 4 to Registration 
  Statement on Form N-4, File No. 333-49176, as filed on November 30, 2000.) 
(8.41)  Fund Participation Agreement dated as of November 28, 2001, among Portfolio 
  Partners, Inc., Aetna Life Insurance and Annuity Company and Aetna Investment 
  Services, LLC. (Incorporated herein 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.) 
(8.42)  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 Fund 
  Participation Agreement dated November 28, 2001. (Incorporated herein 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.) 
(8.43)  Amendment dated May 1, 2003, between ING Partners, Inc., ING Life Insurance and 
  Annuity Company and ING Financial Advisers, LLC to Fund Participation Agreement 
  dated November 28, 2001, and subsequently amended on March 5, 2002. (Incorporated 
  herein 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)  Amendment dated November 1, 2004, to the Fund 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, 
  and May 1, 2003. (Incorporated herein 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.) 
(8.45)  Amendment dated April 29, 2005, to the Fund 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, and November 1, 2004. (Incorporated herein 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.) 
(8.46)  Amendment dated August 31, 2005, to the Fund Participation Agreement between ING 
  Partners, Inc., ING Life Insurance and Annuity Company and ING Financial Advisers, 
  LLC dated November 28, 2001, subsequently amended on March 5, 2002, May 1, 2003, 
  and November 1, 2004, and April 29, 2005. (Incorporated herein 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.) 


(8.47)  Amendment dated December 7, 2005, to the Fund Participation Agreement between 
  ING Partners, Inc., ING Life Insurance and Annuity Company and ING Financial 
  Advisers, LLC dated November 28, 2001, subsequently amended on March 5, 2002, 
  May 1, 2003, November 1, 2004, April 29, 2005, and August 31, 2005. (Incorporated 
  herein 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.) 
(8.48)  Shareholder Servicing Agreement (Service Class Shares) dated as of November 27, 
  2001, between Portfolio Partners, Inc. and Aetna Life Insurance and Annuity Company. 
  (Incorporated herein by reference to Post-Effective Amendment No. 30 to Registration 
  Statement on Form N-4, File No. 333-75962, as filed on April 8, 2002.) 
(8.49)  Amendment dated March 5, 2002, between Portfolio Partners (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 herein by 
  reference to Post-Effective Amendment No. 30 to Registration Statement on Form N-4, 
  File No. 333-75962, as filed on April 8, 2002.) 
(8.50)  Amendment dated May 1, 2003, by and between ING Portfolio Partners, Inc. to the 
  Shareholder Servicing Agreement (Service Class Shares) dated November 27, 2001, as 
  amended on March 5, 2002. (Incorporated herein by reference to Post-Effective 
  Amendment No. 28 to Registration Statement on Form N-4, File No. 33-75988, as filed 
  on April 1, 2003.) 
(8.51)  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 herein by reference to Post-Effective Amendment No. 56 to 
  Registration Statement on Form N-4, File No. 33-34370, as filed on April 17, 2006.) 
(8.52)  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 as amended on March 5, 2002, May 1, 2003, 
  and November 1, 2004. (Incorporated herein 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.) 
(8.53)  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, as amended on March 5, 2002, May 1, 
  2003, November 1, 2004, and April 29, 2005. (Incorporated herein by reference to Post- 
  Effective Amendment No. 56 to Registration Statement on Form N-4, File No. 33- 
  34370, as filed on April 17, 2006.) 
(8.54)  Fund Participation Agreement dated July 29, 1992, and amended December 22, 1991, 
  and June 1, 1994, between Aetna Life Insurance and Annuity Company, Investors 
  Research Corporation and TCI Portfolios, Inc. (Incorporated herein 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.) 
(8.55)  Rule 22c-2 Agreement dated no later than April 16, 2007, is effective October 16, 2007, 
  between ING Funds Services, LLC, ING Life Insurance and Annuity Company, ING 
  National Trust, ING USA Annuity and Life Insurance Company, ReliaStar Life 
  Insurance Company, ReliaStar Life Insurance Company of New York, Security Life of 
  Denver Insurance Company and Systematized Benefits Administrators Inc. 
  (Incorporated herein by reference to Post-Effective Amendment No. 50 to Registration 
  Statement on Form N-4, File No. 33-75962, as filed on June 15, 2007. 
(9)  Opinion and Consent of Counsel, attached 
(10)  Consent of Independent Registered Public Accounting Firm, attached. 
(11)  Not Applicable 
(12)  Not Applicable 


(13)  Authorization for Signatures. (Incorporated herein by reference to Post-Effective 
  Amendment No. 5 to Registration Statement on Form N-4, File No. 33-75986, as filed 
  on April 2, 1996.) 
(14)  Powers of Attorney, attached. 

Item 25  Directors and Officers of the Depositor   
  Name and Principal Business Address                         Positions and Offices with Depositor 
Thomas J. McInerney, One Orange Way, Windsor, CT  Director and Chairman 
         06095-4774   
Catherine H. Smith, One Orange Way, Windsor, CT  President and Director 
         06095-4774   
David A. Wheat, 5780 Powers Ferry Road, NW, Atlanta,  Director, Executive Vice President and Chief Financial 
         GA 30327       Officer 
Bridget M. Healy, 230 Park Avenue, New York, NY  Director 
         10169   
Donald W. Britton, 5780 Powers Ferry Road, Atlanta,  Director 
         GA 30327-4390   
Valerie G. Brown, 5780 Powers Ferry Road, NW,  Senior Vice President 
         Atlanta, GA 30327   
Sue A. Collins, One Orange Way, Windsor, CT 06095-  Senior Vice President and Chief Actuary 
         4774   
Boyd G. Combs, 5780 Powers Ferry Road, NW, Atlanta,  Senior Vice President, Tax 
         GA 30327   
Brian D. Comer, One Orange Way, Windsor, CT 06095-  Senior Vice President 
         4774   
Ralph Ferraro, One Orange Way,Windsor, CT 06095-  Senior Vice President 
         4774   
Daniel P. Hanlon, One Orange Way, Windsor, CT  Senior Vice President 
         06095-4774   
Shawn P. Matthews, 10 State House Square, Hartford,  Senior Vice President 
         CT 06103   
David S. Pendergrass, 5780 Powers Ferry Road, NW,  Senior Vice President and Treasurer 
         Atlanta, GA 30327   
Steven T. Pierson, 5780 Powers Ferry Road, NW,  Senior Vice President and Chief Accounting Officer 
         Atlanta, GA 30327   
Stephen J. Preston, 1475 Dunwoody Drive, West  Senior Vice President 
         Chester, PA 19380   
Joseph Elmy, 1475 Dunwoody Drive, West Chester, PA  Vice President, Tax 
         19380   
Linda E. Senker, 1475 Dunwoody Drive, West Chester,  Vice President, Compliance 
         PA 19380-1478   
Joy M. Benner, 20 Washington Avenue South,  Secretary 
         Minneapolis, MN 55401   

Item 26.  Persons Controlled by or Under Common Control with the Depositor or Registrant 
  Incorporated herein by reference to Item 28 in Post-Effective Amendment No. 26 to Registration 
  Statement on Form N-6 for Security Life Separate Account L1 of Security Life of Denver Insurance 
  Company (File No. 33-57244), as filed with the Securities and Exchange Commission on April 7, 
  2009. 
 
Item 27.  Number of Contract Owners 
  As of April 30, 2009, there were 58,179 individuals holding interests in variable annuity contacts 
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.

A corporation may procure indemnification insurance on behalf of an individual who is or was a director of the corporation. Consistent with the laws of the State of Connecticut, ING America Insurance Holdings, Inc. maintains a Professional Liability and fidelity bond insurance policy issued by an international insurer. The policy covers ING America Insurance Holdings, Inc. and any company in which ING America Insurance Holdings, Inc. has a controlling financial interest of 50% or more. These policies include the principal underwriter, as well as, the depositor. Additionally, the parent company of ING America Insurance Holdings, Inc., ING Groep N.V., maintains excess umbrella coverage with limits in excess of €125,000,000. The policies provide for the following types of coverage: errors and omissions/professional liability, 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. Barhorst, 4225 Executive Square, La Jolla,  President and Director 
         CA 92037   
Kristin H. Hultgren, One Orange Way, Windsor, CT  Chief Financial Officer 
         06095   
Libby J. Soong, One Orange Way, Windsor, CT 06095-  Chief Compliance Officer 
         4774   
Brian D. Comer, One Orange Way, Windsor, CT 06095-  Senior Vice President and Director 
         4774   
Randall Ciccati, 400 First Street, St. Cloud, MN 56301  Director 
Boyd G. Combs, 5780 Powers Ferry Road, N.W.,  Senior Vice President , Tax 
         Atlanta, GA 30327   
Daniel P. Hanlon, One Orange Way, Windsor, CT  Senior Vice President 
         06095-4774   
William S. Jasien, 12701 Fair Lakes Circle, Ste 470,  Senior Vice President 
         Fairfax, VA 22033   
Joseph J. Elmy, 5780 Powers Ferry Road, N.W.,  Vice President, Tax 
         Atlanta, GA 30327   
David S. Pendergrass, 5780 Powers Ferry Road, NW,  Vice President and Treasurer 
         Atlanta, GA 30327   
Joy M. Benner, 20 Washington Avenue S, Minneapolis,  Secretary 
         MN 55401   


(c)  Compensation from January 1, 2008 to December 31, 2008:     
  (1)  (2)  (3)  (4)  (5) 
    Net       
  Name of  Underwriting  Compensation on     
  Principal  Discounts and  Redemption or  Brokerage   
  Underwriter  Commissions  Annuitization  Commissions  Compensation* 
  ING Financial         
  Advisers, LLC        $2,501,353 

* Reflects compensation paid to ING Financial Advisers, LLC attributable to regulatory and operating expenses 
associated with the distribution of al registered variable annuity products issued by Variable Annuity Account B 
of ING Life Insurance and Annuity Company during 2008. 
 
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, CT 06095-4774 
  and ING Americas at 5780 Powers Ferry Road, Atlanta, GA 30327-4390 and 1475 Dunwoody Drive, 
  West Chester, PA 19380-1478. 
 
 
Item 31.  Management Services 
  Not Applicable 
 
Item 32.  Undertakings 
  Registrant hereby undertakes: 
  (i)  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; 
  (ii)  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 or a post card or similar written communication affixed to or included 
    in the Prospectus that the applicant can remove to send for a Statement of Additional Information; 
    and 
  (iii)  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, expenses expected 
to be incurred, and the risks assumed by ING Life Insurance and Annuity Company. 


The Depositor and Registrant rely on SEC regulation.


SIGNATURES

Pursuant to the requirements of the Securities Act of 1933 and the Investment Company Act of 1940, the Registrant, Variable Annuity Account B, certifies that it meets all the requirements for effectiveness of this Registration Statement under Rule 485(b) under the Securities Act of 1933 and has duly caused this Post-Effective Amendment No. 62 to this Registration Statement to be signed on its behalf by the undersigned, duly authorized, in the Town of Windsor, and State of Connecticut on the 24th day of June, 2009.

VARIABLE ANNUITY ACCOUNT B 
(Registrant) 
 
 
By: ING LIFE INSURANCE AND ANNUITY COMPANY 
  (Depositor) 
 
By:                                      
           Catherine H. Smith* 
           President and Director 
           (principal executive officer) 
 
By:           /s/ J. Neil McMurdie 
           J. Neil McMurdie as 
           Attorney-in-Fact 

Pursuant to the requirements of the Securities Act of 1933, this Post-Effective Amendment No. 62 to the 
Registration Statement has been signed by the following persons in the capacities indicated on June 24, 2009. 
 
Signature  Title 
 
  President and Director 
Catherine H. Smith*  (principal executive officer) 
 
  Director 
Bridget M. Healy*   
 
  Director 
Donald W. Britton*   
 
  Director and Chairman 
Thomas J. McInerney*   
 
  Director, Executive Vice President and Chief Financial 
David A. Wheat*  Officer (principal financial officer) 
 
  Senior Vice President and Chief Accounting Officer 
Steven T. Pierson*  (principal accounting officer) 
 
By: /s/ J. Neil McMurdie   
     J. Neil McMurdie as   
     Attorney-in-Fact   

* Executed by J. Neil McMurdie on behalf of those indicated pursuant to Powers of Attorney.


  VARIABLE ANNUITY ACCOUNT B   
  EXHIBIT INDEX   
Exhibit No.  Exhibit   
24(b)(9)  Opinion and Consent of Counsel  EX-99.B9 
24(b)(10)  Consent of Independent Registered Public Accounting Firm  EX-99.B10 
24(b)(14)  Powers of Attorney  EX-99.B14