ING Life Insurance and Annuity Company
                                                                        and its
                                                    Variable Annuity Account C

                 State University of New York Defined Contribution Retirement Plan

                Supplement dated September 18, 2007 to the Contract Prospectus and
                      Contract Prospectus Summary dated April 30, 2007, as amended

The following information updates and amends certain information contained in your variable annuity Contract
Prospectus and Contract Prospectus Summary. Please read it carefully and keep it with your current variable
annuity Contract Prospectus and/or Contract Prospectus Summary for future reference.

                    IMPORTANT INFORMATION REGARDING AN UPCOMING
                             CHANGE TO OUR EXCESSIVE TRADING POLICY

Effective October 16, 2007, our Excessive Trading Policy will change and the “Limits on Frequent or
Disruptive Transfers,” “The Company Intends to Modify its Excessive Trading Policy in October 2007,” and
“Agreements to Share Information with Funds,” sections of the Contract Prospectus and Contract
Prospectus Summary will be deleted in its entirety and replaced with the following:

Limits on Frequent or Disruptive Transfers

The contract is not designed to serve as a vehicle for frequent transfers. Frequent transfer activity can disrupt
management of a fund and raise its expenses through:
•      Increased trading and transaction costs;
•      Forced and unplanned portfolio turnover;
•      Lost opportunity costs; and
•      Large asset swings that decrease the fund’s ability to provide maximum investment return to all contract owners
        and participants.

This in turn can have an adverse effect on fund performance. Accordingly, individuals or organizations that use
market-timing investment strategies or make frequent transfers should not purchase or participate in the
contract.

Excessive Trading Policy. We and the other members of the ING family of companies that provide multi-fund
variable insurance and retirement products have adopted a common Excessive Trading Policy to respond to the
demands of the various fund families that make their funds available through our products to restrict excessive fund
trading activity and to ensure compliance with Rule 22c-2 of the 1940 Act.

We actively monitor fund transfer and reallocation activity within our variable insurance products to identify
violations of our Excessive Trading Policy. Our Excessive Trading Policy is violated if fund transfer and
reallocation activity:
•      Meets or exceeds our current definition of Excessive Trading, as defined below; or
•      Is determined, in our sole discretion, to be disruptive or not in the best interests of other owners of our variable
        insurance and retirement products, or participants in such products.

We currently define Excessive Trading as:
•      More than one purchase and sale of the same fund (including money market funds) within a 60 calendar day
        period (hereinafter, a purchase and sale of the same fund is referred to as a “round-trip”). This means two or
        more round-trips involving the same fund within a 60 calendar day period would meet our definition of
        Excessive Trading; or
•      Six round-trips involving the same fund within a rolling twelve month period.

X.81216-07C 1 of 3 September 2007

The following transactions are excluded when determining whether trading activity is excessive:
•     Purchases or sales of shares related to non-fund transfers (for example, new purchase payments, withdrawals
        and loans);
•     Transfers associated with scheduled dollar cost averaging, scheduled rebalancing, or scheduled asset allocation
programs;
•     Purchases and sales of fund shares in the amount of $5,000 or less;
•     Purchases and sales of funds that affirmatively permit short-term trading in their fund shares, and movement
between such funds and a money market fund; and
•     Transactions initiated by us, another member of the ING family of companies, or a fund.

If we determine that an individual or entity has made a purchase of a fund within 60 days of a prior round-trip
involving the same fund, we will send them a letter (once per year) warning that another sale of that same fund
within 60 days of the beginning of the prior round-trip will be deemed to be Excessive Trading and result in a six
month suspension of their ability to initiate fund transfers or reallocations through the Internet, facsimile, Voice
Response Unit (VRU), telephone calls to the ING Customer Service Center, or other electronic trading medium that
we may make available from time to time (“Electronic Trading Privileges”). Likewise, if we determine that an
individual or entity has made five round-trips involving the same fund within a rolling twelve month period, we will
send them a letter warning that another purchase and sale of that same fund within twelve months of the initial
purchase in the first round-trip will be deemed to be Excessive Trading and result in a suspension of their Electronic
Trading Privileges. According to the needs of the various business units, a copy of any warning letters may also be
sent, as applicable, to the person(s) or entity authorized to initiate fund transfers or reallocations, the agent/registered
representative, or the investment adviser for that individual or entity. A copy of the warning letters and details of
the individual’s or entity’s trading activity may also be sent to the fund whose shares were involved in the trading
activity.

If we determine that an individual or entity has violated our Excessive Trading Policy, we will send them a letter
stating that their Electronic Trading Privileges have been suspended for a period of six months. Consequently, all
fund transfers or reallocations, not just those that involve the fund whose shares were involved in the activity that
violated our Excessive Trading Policy, will then have to be initiated by providing written instructions to us via
regular U.S. mail. Suspension of Electronic Trading Privileges may also extend to products other than the product
through which the Excessive Trading activity occurred. During the six month suspension period, electronic “inquiry
only” privileges will be permitted where and when possible. A copy of the letter restricting future transfer and
reallocation activity to regular U.S. mail and details of the individual’s or entity’s trading activity may also be sent,
as applicable, to the person(s) or entity authorized to initiate fund transfers or reallocations, the agent/registered
representative or investment adviser for that individual or entity, and the fund whose shares were involved in the
activity that violated our Excessive Trading Policy.

Following the six month suspension period during which no additional violations of our Excessive Trading Policy
are identified, Electronic Trading Privileges may again be restored. We will continue to monitor the fund transfer
and reallocation activity, and any future violations of our Excessive Trading Policy will result in an indefinite
suspension of Electronic Trading Privileges. A violation of our Excessive Trading Policy during the six month
suspension period will also result in an indefinite suspension of Electronic Trading Privileges.

We reserve the right to suspend Electronic Trading Privileges with respect to any individual or entity, with or
without prior notice, if we determine, in our sole discretion, that the individual’s or entity’s trading activity is
disruptive or not in the best interests of other owners of our variable insurance and retirement products, or
participants in such products, regardless of whether the individual’s or entity’s trading activity falls within the
definition of Excessive Trading set forth above.

Our failure to send or an individual’s or entity’s failure to receive any warning letter or other notice contemplated
under our Excessive Trading Policy will not prevent us from suspending that individual’s or entity’s Electronic
Trading Privileges or taking any other action provided for in our Excessive Trading Policy.

X.81216-07C 2 of 3 September 2007

The Company does not allow exceptions to our Excessive Trading Policy. We reserve the right to modify our
Excessive Trading Policy, or the policy as it relates to a particular fund, at any time without prior notice, depending
on, among other factors, the needs of the underlying fund(s), the best interests of contract owners, participants, and
fund investors, and/or state or federal regulatory requirements. If we modify our policy, it will be applied uniformly
to all contract owners and participants or, as applicable, to all contract owners and participants investing in the
underlying fund.

Our Excessive Trading Policy may not be completely successful in preventing market-timing or excessive trading
activity. If it is not completely successful, fund performance and management may be adversely affected, as noted
above.

Limits Imposed by the Funds. Each underlying fund available through the variable insurance and retirement
products offered by us and/or the other members of the ING family of companies, either by prospectus or stated
policy, has adopted or may adopt its own excessive/frequent trading policy, and orders for the purchase of fund
shares are subject to acceptance or rejection by the underlying fund. We reserve the right, without prior notice, to
implement fund purchase restrictions and/or limitations on an individual or entity that the fund has identified as
violating its excessive/frequent trading policy and to reject any allocation or transfer request to a subaccount if the
corresponding fund will not accept the allocation or transfer for any reason. All such restrictions and/or limitations
(which may include, but are not limited to, suspension of Electronic Trading Privileges and/or blocking of future
purchases of a fund or all funds within a fund family) will be done in accordance with the directions we receive from
the fund.

Agreements to Share Information with Fund Companies. As required by Rule 22c-2 under the 1940 Act, we
have entered into information sharing agreements with each of the fund companies whose funds are offered through
the contract. Contract owner and participant trading information is shared under these agreements as necessary for
the fund companies to monitor fund trading and our implementation of our Excessive Trading Policy. Under these
agreements, the Company is required to share information regarding contract owner and participant transactions,
including but not limited to information regarding fund transfers initiated by you. In addition to information about
contract owner and participant transactions, this information may include personal contract owner and participant
information, including names and social security numbers or other tax identification numbers.

As a result of this information sharing, a fund company may direct us to restrict a contract owner or participant’s
transactions if the fund determines that the contract owner or participant has violated the fund’s excessive/frequent
trading policy. This could include the fund directing us to reject any allocations of purchase payments or account
value to the fund or all funds within the fund family.

X.81216-07C 3 of 3 September 2007