EXHIBIT 99-B.9

[ING LOGO]

AMERICAS

US Legal Services

MEGAN L. DUNPHY
COUNSEL
(860) 273-1995
FAX:  (860) 273-3227


April 10, 2002

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC  20549

RE:   ING LIFE INSURANCE AND ANNUITY COMPANY (FORMERLY AETNA LIFE INSURANCE AND
      ANNUITY COMPANY) AND ITS VARIABLE ANNUITY ACCOUNT B
      POST-EFFECTIVE AMENDMENT NO. 27 TO REGISTRATION STATEMENT ON FORM N-4
      PROSPECTUS TITLE:  GROUP VARIABLE ANNUITY CONTRACTS FOR EMPLOYER-SPONSORED
                         DEFERRED COMPENSATION PLANS
      FILE NOS. 33-75996* AND 811-2512

Dear Sir or Madam:

The undersigned serves as counsel to ING Life Insurance and Annuity Company, a
Connecticut life insurance company (the "Company").  It is my understanding
that the Company, as depositor, has registered an indefinite amount of
securities (the "Securities") under the Securities Act of 1933 (the "Securities
Act") as provided in Rule 24f-2 under the Investment Company Act of 1940 (the
"Investment Company Act").

In connection with this opinion, I have reviewed the N-4 Registration
Statement, as amended to the date hereof, and this Post-Effective Amendment No.
27.  I have also examined originals or copies, certified or otherwise
identified to my satisfaction, of such documents, trust records and other
instruments I have deemed necessary or appropriate for the purpose of rendering
this opinion.  For purposes of such examination, I have assumed the genuineness
of all signatures on original documents and the conformity to the original of
all copies.


--------------------------
*   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 securities covered by Registration Statement
    No. 2-52448 and the individual deferred compensation contracts covered by
    Registration Statement No. 33-76000.



Hartford Site                            ING North America Insurance Corporation
151 Farmington Avenue, TS31
Hartford, CT 06156-8975

Page 2
Securities and Exchange Commission


I am admitted to practice law in Connecticut, and do not purport to be an
expert on the laws of any other state.  My opinion herein as to any other law
is based upon a limited inquiry thereof which I have deemed appropriate under
the circumstances.

Based upon the foregoing, and, assuming the Securities are sold in accordance
with the provisions of the prospectus, I am of the opinion that the Securities
being registered will be legally issued and will represent binding obligations
of the Company.

I consent to the filing of this opinion as an exhibit to the Registration
Statement.

Sincerely,

/s/ Megan L. Dunphy

Megan L. Dunphy