Exhibit 99-B.9

AMERICAS
US Legal Services

Michael A. Pignatella
Counsel
(860) 580-2831
Fax: (860) 580-4934
michael.pignatella@us.ing.com

June 27, 2008

Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

Attention: Filing Desk

Re: ING Life Insurance and Annuity Company (formerly Aetna Life Insurance and
Annuity Company) and its Variable Annuity Account C
Post-Effective Amendment No. 42 to Registration Statement on Form N-4
Prospectus Title: Pension IRA– Individual Deferred Variable Annuity Contracts for
Individual Retirement Annuities (Section 408(b)) and Simplified Employee Pension
Plans (Section 408(k))
File Nos. 33-75988^* and 811-02513

Ladies and Gentlemen:

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”).

*      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 prospectuses relating to the securities covered by the following earlier Registration Statements: 33-75972; 33-76024; and 33-89858.

Windsor Site
One Orange Way
Windsor, CT 06095-4774 ING North America Insurance Corporation

In connection with this opinion, I have reviewed the N-4 Registration, as amended to the date
hereof, and this Post-Effective Amendment No. 42. 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
purpose of such examination, I have assumed the genuineness of all signatures on original
documents and the conformity to the original of all copies.

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/ Michael A. Pignatella

Michael A. Pignatella