As filed with the Securities and Exchange		Registration No. 033-75988*
Commission on June 27, 2008		Registration No. 811-02513
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM N-4
Post-Effective Amendment No. 42 To
REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933
and Amendment to
REGISTRATION STATEMENT UNDER THE INVESTMENT COMPANY ACT OF 1940
Variable Annuity Account C of
ING Life Insurance and Annuity Company
One Orange Way, Windsor, Connecticut 06095-4774
Depositor’s Telephone Number, including Area Code: (860) 580-2831
Michael A. Pignatella, Counsel
ING US Legal Services
One Orange Way, C1S, Windsor, Connecticut 06095-4774
(Name and Address of Agent for Service)
It is proposed that this filing will become effective:
X	immediately upon filing pursuant to paragraph (b) of Rule 485
	on  __________	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: Individual, Deferred, Fixed and 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 securities covered by the following earlier
Registration Statements: 033-75972; 033-76024; and 033-89858.

                                                              PARTS A AND B

The Prospectus and the Statement of Additional Information each dated April 28, 2008 are
incorporated into Parts A and B, respectively, of this Post-Effective Amendment No. 42 by
reference to Registrant’s filing under Rule 497(c) as filed on April 29, 2008.

A supplement dated June 27, 2008 to the Prospectus and Statement of Additional Information is
included in Parts A and B, respectively, of this Post-Effective Amendment No. 42.

ING Life Insurance and Annuity Company 

and its

Variable Annuity Account C

ING Pension IRA

         Supplement dated June 27, 2008 to the Contract Prospectus and Statement of Additional
                                       Information, each dated April 28, 2008, as amended

The information in this Supplement updates and amends certain information contained in your variable
annuity Contract Prospectus and Statement of Additional Information (SAI). Please read it carefully and
keep it with your current variable annuity Contract Prospectus and SAI for future reference.

1.      On March 27, 2008, the Board of Trustees of ING Variable Products Trust and ING Investors Trust approved a proposal to reorganize the following “Disappearing Portfolio” into the following “Surviving Portfolio.” Subject to approval by the Portfolio’s shareholders, after the close of business on September 5, 2008 the following Disappearing Portfolio will reorganize into and become part of the following Surviving Portfolio:

Disappearing Portfolio	Surviving Portfolio
ING VP Real Estate Portfolio	ING Global Real Estate Portfolio

Accordingly, effective after the close of business on September 5, 2008, investments in the
Disappearing Portfolio will automatically become investments in the Surviving Portfolio, as follows:

• Class I of the ING Global Real Estate Portfolio will automatically be added to your contract and all existing account
  balances invested in the ING VP Real Estate Portfolio (Class I) will automatically become investments in the ING
  Global Real Estate Portfolio (Class I).

As a result of the reorganization, effective September 8, 2008 all references to the Disappearing
Portfolio in the Contract Prospectus and SAI are hereby deleted.

Unless you provide us with alternative allocation instructions, all future allocations directed to the
Disappearing Portfolio 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
home office through:

ING
USFS Customer Service
Defined Contribution Administration
P.O. Box 990063
Hartford, CT 06199-0063
1-800-262-3862

See also the Transfers section of your Contract Prospectus for further information about
making fund allocation changes.

X.75988-08A                                                   Page 1 of 2                                                   June 2008

2.      The information for ING Julius Baer Foreign Portfolio appearing in the Contract Prospectus under Appendix IV – Description of Underlying Funds is deleted and replaced with the following to reflect a subadviser name change effective June 15, 2008. In addition, effective September 8, 2008, the following information for ING Global Real Estate Portfolio is added to Appendix IV – Description of Underlying Funds.

	Investment	Investment
Fund Name	Adviser/Subadviser	Objective(s)
ING Investors Trust – ING	ING Investments, LLC	Seeks high total return
Global Real Estate		consisting of capital
Portfolio	Subadviser: ING Clarion	appreciation and current
	Real Estate Securities L.P.	income.
ING Investors Trust – ING	Directed Services LLC	Seeks long-term growth of
Julius Baer Foreign		capital.
Portfolio	Subadviser: Artio Global
	Management, LLC

3.      The minimum and maximum Total Annual Fund Operating Expenses shown in the Contract Prospectus will not change as a result of the reorganizations. Therefore, there is no change to the hypothetical examples shown in the Contract Prospectus.

X.75988-08A                                                                  Page 2 of 2                                       June 2008

                                               VARIABLE ANNUITY ACCOUNT C
                                                PART C - OTHER INFORMATION

Item 24. Financial Statements and Exhibits

(a)	Financial Statements:
	(1)	Incorporated by reference in Part A: Condensed Financial Information
	(2)	Incorporated by reference in Part B:
		Financial Statements of Variable Annuity Account C:
			Report of Independent Registered Public Accounting Firm
			Statements of Assets and Liabilities as of December 31, 2007
			Statements of Operations for the year ended December 31, 2007
			Statements of Changes in Net Assets for the years ended December 31, 2007 and 2006
			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, 2007, 2006 and 2005
			Consolidated Balance Sheets as of December 31, 2007 and 2006
			Consolidated Statements of Changes in Shareholder’s Equity for the years ended December 31, 2007, 2006 and 2005
			Consolidated Statements of Cash Flows for the years ended December 31, 2007, 2006 and 2005
			Notes to Consolidated Financial Statements

(b)	Exhibits
	(1)	Resolution establishing Variable Annuity Account C • Incorporated by reference to Post-Effective Amendment No. 6 to Registration Statement on Form N-4 (File No.
		033-75986), 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. 033-
	81216), as filed on April 11, 2006.
(3.2)	Underwriting Agreement dated November 17, 2006 between ING Life Insurance and
	Annuity Company and ING Financial Advisers, LLC •Incorporated by reference to
	Post-Effective Amendment No. 34 to Registration Statement on Form N-4 (File No.
	033-75996), as filed on December 20, 2006.
(4.1)	Variable Annuity Contracts (IRA-CDA-IC) and (IP-CDA-IB) •Incorporated by
	reference to Post-Effective Amendment No. 4 to Registration Statement on Form N-4
	(File No. 033-75988), as filed on April 15, 1996.
(4.2)	Variable Annuity Contract IRA-CDA-03 •Incorporated by reference to Post-
	Effective Amendment No. 8 to Registration Statement on Form N-4 (File No. 033-
	75988), as filed on April 17, 1997.
(4.3)	Variable Annuity Contract IRA-CDA-03(NY) •Incorporated by reference to Post-

	Effective Amendment No. 8 to Registration Statement on Form N-4 (File No. 033-
	75988), as filed on April 17, 1997.
(4.4)	Contract Schedule IMSIRA-03 to Variable Annuity Contract IRA-CDA-03 •
	Incorporated by reference to Post-Effective Amendment No. 8 to Registration
	Statement on Form N-4 (File No. 033-75988), as filed on April 17, 1997.
(4.5)	Contract Schedule IROIRA-03 to Variable Annuity Contract IRA-CDA-03 •
	Incorporated by reference to Post-Effective Amendment No. 8 to Registration
	Statement on Form N-4 (File No. 033-75988), as filed on April 17, 1997.
(4.6)	Contract Schedule IROPIRA-03 to Variable Annuity Contract IRA-CDA-03 •
	Incorporated by reference to Post-Effective Amendment No. 8 to Registration
	Statement on Form N-4 (File No. 033-75988), as filed on April 17, 1997.
(4.7)	Contract Schedule IMSIRA-03(NY) to Variable Annuity Contract IRA-CDA-03(NY)
	•Incorporated by reference to Post-Effective Amendment No. 8 to Registration
	Statement on Form N-4 (File No. 033-75988), as filed on April 17, 1997.
(4.8)	Contract Schedule IROIRA-03(NY) to Variable Annuity Contract IRA-CDA-03(NY)
	•Incorporated by reference to Post-Effective Amendment No. 8 to Registration
	Statement on Form N-4 (File No. 033-75988), as filed on April 17, 1997.
(4.9)	Contract Schedule IROPIRA-03(NY) to Variable Annuity Contract IRA-CDA-
	03(NY) •Incorporated by reference to Post-Effective Amendment No. 8 to
	Registration Statement on Form N-4 (File No. 033-75988), as filed on April 17, 1997.
(4.10)	Endorsement EIRA-ROTH-03(NY) to Variable Annuity Contract IRA-CDA-03(NY)
	•Incorporated by reference to Post-Effective Amendment No. 8 to Registration
	Statement on Form N-4 (File No. 033-75988), as filed on April 17, 1997.
(4.11)	Endorsement EIRA-ROTH-03 to Variable Annuity Contract IRA-CDA-03 •
	Incorporated by reference to Post-Effective Amendment No. 8 to Registration
	Statement on Form N-4 (File No. 033-75988), as filed on April 17, 1997.
(4.12)	Endorsements (EIRA-SDOIC-97) and (EIRA-SDOIC-97(NY)) to Variable Annuity
	Contract IRA-CDA-IC •Incorporated by reference to Post-Effective Amendment No.
	30 to Registration Statement on Form N-4 (File No. 033-75988), as filed on
	December 30, 2003.
(4.13)	Endorsement (EIP-SDOIB-97) to Variable Annuity Contract IP-CDA-IB •
	Incorporated by reference to Post-Effective Amendment No. 30 to Registration
	Statement on Form N-4 (File No. 033-75988), as filed on December 30, 2003.
(4.14)	Endorsement (EPIRA-GI-98) to Contract IRA-CDA-IC •Incorporated by reference
	to Post-Effective Amendment No. 12 to Registration Statement on Form N-4 (File
	No. 033-75988), as filed on September 15, 1998.
(4.15)	Endorsement (EIGET-IC(R)) to Contracts IRA-CDA-IC and IP-CDA-IB •
	Incorporated by reference to Post-Effective Amendment No. 8 to Registration
	Statement on Form N-4 (File No. 033-75964), as filed on August 30, 1996.
(4.16)	Endorsement (EGET-99) to Contracts IRA-CDA-IC and IP-CDA-IB •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.
(4.17)	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. 033-75962), as filed on April 8, 2002.
(4.18)	Contract Schedule (IROPIRA-99) to Contract IRA-CDA-IC •Incorporated by
	reference to Post-Effective Amendment No. 16 to Registration Statement on Form N-
	4 (File No. 033-75988), as filed on August 24, 1999.
(4.19)	Endorsement EEGTRRA-PENIRA(01) to Contracts IRA-CDA-IC and IP-CDA-IB •
	Incorporated by reference to Post-Effective Amendment No. 26 to Registration
	Statement on Form N-4 (File No. 033-75988), as filed on April 15, 2002.
(4.20)	Contract Schedule (IROIRA-99) to Contract IRA-CDA-IC •Incorporated by
	reference to Post-Effective Amendment No. 16 to Registration Statement on Form N-
	4 (File No. 033-75988), as filed on August 24, 1999.
(4.21)	Contract Schedule (IMSIRA-99) to Contract IRA-CDA-IC •Incorporated by
	reference to Post-Effective Amendment No. 16 to Registration Statement on Form N-
	4 (File No. 033-75988), as filed on August 24, 1999.
(4.22)	Endorsement EIRAGMDB-04 to Contracts IRA-CDA-IC and IP-CDA-IB •
	Incorporated by reference to Post-Effective Amendment No. 31 to Registration
	Statement Form N-4 (File No. 033-75988), as filed on February 19, 2004.
(5.1)	Variable Annuity Contract Application (304.00.1A) • Incorporated by reference to
	Post-Effective Amendment No. 10 to Registration Statement Form N-4 (File No.
	033-75988), as filed on October 30, 1997.
(5.2)	Variable Annuity Contract Application (703.00.1A) • Incorporated by reference to
	Post-Effective Amendment No. 9 to Registration Statement on Form N-4 (File No.
	033-75988), as filed on August 18, 1997.
(5.3)	Variable Annuity Contract Application (75988-97) •Incorporated by reference to
	Post-Effective Amendment No. 11 to Registration Statement on Form N-4 (File No.
	033-75988), as filed on April 20, 1998.
(5.4)	Variable Annuity Contract Application (75988-04) •Incorporated by reference to
	Post-Effective Amendment No. 8 to Registration Statement on Form N-4 (File No.
	033-75988), as filed on April 17, 1997.
(5.5)	Variable Annuity Contract Application (75988-04)(NY) •Incorporated by reference
	to Post-Effective Amendment No. 8 to Registration Statement on Form N-4 (File No.
	033-75988), as filed on April 17, 1997.
(6.1)	Restated Certificate of Incorporation (amended and restated as of January 1, 2002) of
	ING Life Insurance and Annuity Company •Incorporated by reference to ING Life
	Insurance and Annuity Company annual report on Form 10-K (File No. 033-23376),
	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.), 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.
(8.3)	First Amendment dated November 17, 2000 to Fund 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 20,
	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 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. 033-75988), 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)	Rule 22c-2 Agreement dated no later than April 16, 2007 and is effective as of
	October 16, 2007 between AIM Investment Services, 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 by reference to Post-Effective Amendment No. 50
	to Registration Statement on Form N-4 (File No. 033-75962), as filed on June 15,
	2007.
(8.8)	Participation Agreement effective as of March 1, 2000 among Aetna Life Insurance
	and Annuity Company, Alliance Fund Distributors, Inc., and Alliance Capital
	Management L.P. •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)	Service Agreement effective as of March 1, 2000 among Aetna Life Insurance and
	Annuity Company and Alliance Capital Management L.P. •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.
(8.10)	Rule 22c-2 Agreement dated no later than April 16, 2007 and is effective as of
	October 16, 2007 between AllianceBernstein Investor Services, 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 by reference to Post-
	Effective Amendment No. 41 to Registration Statement on Form N-4 (File No. 033-
	75988), as filed on April 9, 2008.
(8.11)	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 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.
(8.12)	Service Agreement dated December 1, 1997 between Calvert Asset Management
	Company, Inc. and Aetna Life Insurance and Annuity Company •Incorporated 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.
(8.13)	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 by reference to Post-Effective Amendment No. 50
	to Registration Statement on Form N-4 (File No. 033-75962), as filed on June 15,
	2007.
(8.14)	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. 033-75964), as
	filed on February 11, 1997.
(8.15)	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, 1996, 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. 033-34370), as filed on September 29, 1997.
(8.16)	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. 033-75964), as filed on
	February 9, 1998.
(8.17)	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.
(8.18)	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 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.
(8.19)	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 and May 1,
	1998 between ING Life Insurance and Annuity Company (formerly known as Aetna
	Life Insurance and Annuity Company), Variable Insurance Products Fund and Fidelity
	Distributors Corporation •Incorporated 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.
(8.20)	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. 033-75964), as
	filed on February 11, 1997.
(8.21)	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, 1996, 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. 033-34370), as filed on September 29, 1997.
(8.22)	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. 033-75248), as filed on
	February 24, 1998.
(8.23)	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.
(8.24)	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.
(8.25)	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, January 20, 1998 and May 1,
	1998 between ING Life Insurance and Annuity Company (formerly known as Aetna
	Life Insurance and Annuity Company), Variable Insurance Products Fund II and
	Fidelity Distributors Corporation •Incorporated 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.
(8.26)	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 Registration Statement on Form N-4 (File No.
	033-75962), as filed on July 27, 2007.
(8.27)	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. 033-75988), as filed on August 5, 2004.
(8.28)	Service Contract effective as of June 1, 2002 and amended on June 20, 2003 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. 033-75988), as filed on
	August 5, 2004.
(8.29)	First Amendment effective April 1, 2005 to Service Contract between Fidelity
	Distributors Corporation and ING Financial Advisers, Inc. dated June 1, 2002 and
	amended on June 20, 2003 •Incorporated by reference to Post-Effective Amendment
	No. 47 to Registration Statement on Form N-4 (File No. 033-75962), as filed on
	November 21, 2006.
(8.30)	Second Amendment effective April 1, 2006 to Service Contract between Fidelity
	Distributors Corporation and ING Financial Advisers, Inc. dated June 1, 2002 and
	amended on June 20, 2003 and April 1, 2005 •Incorporated by reference to Post-

	Effective Amendment No. 47 to Registration Statement on Form N-4 (File No. 033-
	75962), as filed on November 21, 2006.
(8.31)	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 by reference to Post-Effective Amendment No. 50
	to Registration Statement on Form N-4 (File No. 033-75962), as filed on June 15,
	2007.
(8.32)	Amended and Restated Participation Agreement as of December 30, 2005 by and
	among Franklin Templeton Variable Insurance Products Trust, Franklin/Templeton
	Distributors, Inc., ING Life Insurance and Annuity Company, ING USA Annuity and
	Life Insurance Company, ReliaStar Life Insurance Company, ReliaStar Life Insurance
	Company of New York and Directed Services, Inc. • Incorporated by reference to
	Post-Effective Amendment No. 17 to Registration Statement on Form N-4 (File No.
	333-85618), as filed on February 1, 2007.
(8.33)	Amendment effective June 5, 2007 to Amended and Restated Participation Agreement
	as of December 30, 2005 by and among Franklin Templeton Variable Insurance
	Products Trust, Franklin/Templeton Distributors, Inc., ING Life Insurance and
	Annuity Company, ING USA Annuity and Life Insurance Company, ReliaStar Life
	Insurance Company, ReliaStar Life Insurance Company of New York and Directed
	Services, Inc. • Incorporated by reference to Pre-Effective Amendment No. 1 to
	Registration Statement on Form N-4 (File No. 333-139695), as filed on July 6, 2007.
(8.34)	Amended and Restated Administrative Services Agreement executed as of October 3,
	2005, between Franklin Templeton Services, LLC, ING Life Insurance and Annuity
	Company, ING Insurance Company of America, ING USA Annuity and Life
	Insurance Company and ReliaStar Life Insurance Company •Incorporated by
	reference to Post-Effective Amendment No. 32 to Registration Statement on Form N-
	4 (File No. 033-81216), as filed on April 11, 2006.
(8.35)	Rule 22c-2 Shareholder Information Agreement (Franklin Templeton Variable
	Insurance Products Trust) entered into as of April 16, 2007 among
	Franklin/Templeton Distributors, Inc., ING Life Insurance and Annuity Company,
	ING USA Annuity and Life Insurance Company, ReliaStar Life Insurance Company
	and ReliaStar Life Insurance Company of New York •Incorporated by reference to
	Post-Effective Amendment No. 50 to Registration Statement on Form N-4 (File No.
	033-75962), as filed on June 15, 2007.
(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. 033-23512), as filed on August
	1, 2003.

(8.37)	Amendment dated October 9, 2006 to the Participation Agreement dated April 30,
	2003 among ING Life Insurance and Annuity Company, ING Investors Trust and
	Directed Services, Inc. •Incorporated by reference to Post-Effective Amendment No.
	47 to Registration Statement on Form N-4 (File No. 033-75962), as filed on
	November 21, 2006.
(8.38)	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. 033-75962), as filed on April 8, 2002.
(8.39)	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. 033-75962), as filed on April 8, 2002.
(8.40)	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. 033-75988), as filed on April 10, 2003.
(8.41)	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.
(8.42)	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. 033-
	81216), as filed on April 11, 2006.
(8.43)	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. 033-81216), as filed on April 11, 2006.
(8.44)	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. 033-81216), as filed on April 11, 2006.
(8.45)	Amendment dated April 28, 2006 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, August 31, 2005 and
	December 7, 2005 •Incorporated by reference to Registration Statement on Form N-4
	(File No. 333-134760), as filed on June 6, 2006.
(8.46)	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. 033-75962), as filed on April 8, 2002.
(8.47)	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 (Service Class Shares) dated
	November 27, 2001 •Incorporated by reference to Post-Effective Amendment No. 30
	to Registration Statement on Form N-4 (File No. 033-75962), as filed on April 8,
	2002.
(8.48)	Amendment dated May 1, 2003 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 •
	Incorporated by reference to Post-Effective Amendment No. 28 to Registration
	Statement on Form N-4 (File No. 033-75988), as filed on April 10, 2003.
(8.49)	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 Initial Registration Statement on Form N-4
	(File No. 333-134760), as filed on June 6, 2006.
(8.50)	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. 033-81216), as
	filed on April 11, 2006.
(8.51)	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
	Initial Registration Statement on Form N-4 (File No. 333-134760), as filed on June 6,
	2006.

(8.52)	Amendment dated April 28, 2006 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, April 29, 2005 and December 7, 2005 •Incorporated by reference
	to Registration Statement on Form N-4 (File No. 333-134760), as filed on June 6,
	2006.
(8.53)	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.
(8.54)	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.
(8.55)	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.
(8.56)	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.
(8.57)	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.
(8.58)	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.
(8.59)	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 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. 32
	to Registration Statement n Form N-4 (File No. 033-75988), as filed on April 13,
	2004.
(8.60)	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.
(8.61)	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.
(8.62)	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.
(8.63)	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.
(8.64)	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. 033-75988), as filed on April
	13, 2004.
(8.65)	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.
(8.66)	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. 033-75988), as filed on April 10, 2003.
(8.67)	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. 033-
	75988), as filed on April 10, 2003.
(8.68)	(Retail) Fund Participation Agreement dated January 29, 2001 by and among Aetna
	Life Insurance and Annuity Company and ING Pilgrim Securities, Inc. •Incorporated
	by reference to Post-Effective Amendment No. 41 to Registration Statement on Form
	N-4 (File No. 033-75988), as filed on April 9, 2008.

(8.69)	(Retail) Selling and Services Agreement dated January 29, 2001 by and among Aetna
	Investment Services, LLC, Aetna Life Insurance and Annuity Company and ING
	Pilgrim Securities, Inc. •Incorporated by reference to Post-Effective Amendment No.
	41 to Registration Statement on Form N-4 (File No. 033-75988), as filed on April 9,
	2008.
(8.70)	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 by reference to Post-Effective Amendment No. 50 to Registration
	Statement on Form N-4 (File No. 033-75962), as filed on June 15, 2007.
(8.71)	Fund Participation Agreement dated as of July 20, 2001 between Lord Abbett Series
	Fund, Inc. and Aetna Life Insurance and Annuity Company •Incorporated by
	reference to Post-Effective Amendment No. 27 to Registration Statement on Form N-
	4 (File No. 333-01107), as filed on October 26, 2001.
(8.72)	Service Agreement dated as of July 20, 2001 between Lord Abbett & Co. and Aetna
	Life Insurance and Annuity Company •Incorporated by reference to Post-Effective
	Amendment No. 27 to Registration Statement on Form N-4 (File No. 333-01107), as
	filed on October 26, 2001.
(8.73)	Rule 22c-2 Agreement effective April 16, 2007 and operational on October 16, 2007
	among Lord Abbett Distributor 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 by reference to Post-Effective Amendment No. 50 to Registration
	Statement on Form N-4 (File No. 033-75962), as filed on June 15, 2007.
(8.74)	Fund Participation Agreement dated March 11, 1997 between Aetna Life Insurance
	and Annuity Company and Oppenheimer Variable Annuity Account Funds and
	Oppenheimer Funds, Inc. •Incorporated by reference to Post-Effective Amendment
	No. 27 to Registration Statement on Form N-4 (File No. 033-34370), as filed on April
	16, 1997.
(8.75)	First Amendment dated December 1, 1999 to Fund Participation Agreement between
	Aetna Life Insurance and Annuity Company and Oppenheimer Variable Annuity
	Account Funds and OppenheimerFunds, Inc. dated March 11, 1997 •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.
(8.76)	Second Amendment dated May 1, 2004 to Fund Participation Agreement between
	ING Life Insurance and Annuity Company, OppenheimerFunds, Inc. and
	Oppenheimer Variable Annuity Account Funds dated March 11, 1997 and amended
	December 1, 1999 •Incorporated by reference to Post-Effective Amendment No. 39
	to Registration Statement on Form N-4 (File No. 033-75988), as filed on April 11,
	2007.

(8.77)	Third Amendment dated August 15, 2007 to Fund Participation Agreement between
	ING Life Insurance and Annuity Company, OppenheimerFunds, Inc. and
	Oppenheimer Variable Annuity Account Funds dated March 11, 1997, and amended
	on December 1, 1999 and May 1, 2004 •Incorporated 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.
(8.78)	Service Agreement effective as of March 11, 1997 between OppenheimerFunds, Inc.
	and Aetna Life Insurance and Annuity Company • Incorporated by reference to Post-
	Effective Amendment No. 27 to Registration Statement on Form N-4 (File No. 033-
	34370), as filed on April 16, 1997.
(8.79)	Rule 22c-2 Agreement dated no later than April 16, 2007 and is effective as of
	October 16, 2007 between Oppenheimer Funds Services, 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 by reference to Post-Effective Amendment No. 50
	to Registration Statement on Form N-4 (File No. 033-75962), as filed on June 15,
	2007.
(8.80)	Participation Agreement dated as of May 1, 2004 among ING Life Insurance and
	Annuity Company, ReliaStar Life Insurance Company, PIMCO Variable Insurance
	Trust and PA Distributors LLC •Incorporated by reference to Post-Effective
	Amendment No. 38 to Registration Statement on Form N-4 (File No. 333-01107), as
	filed on February 11, 2005.
(8.81)	First Amendment dated August 15, 2007 to Participation Agreement by and between
	ING Life Insurance and Annuity Company, ReliaStar Life Insurance Company,
	PIMCO Variable Insurance Trust and Allianz Global Investors Distributors LLC dated
	as of May 1, 2004 •Incorporated by reference to Post-Effective Amendment No. 51
	to Registration Statement on Form N-4 (File No. 333-01107), as filed on May 23,
	2008.
(8.82)	Services Agreement dated as of May 1, 2004 between PIMCO Variable Insurance
	Trust (the "Trust"), ING Life Insurance and Annuity Company and ReliaStar Life
	Insurance Company •Incorporated by reference to Post-Effective Amendment No.
	38 to Registration Statement on Form N-4 (File No. 333-01107), as filed on February
	11, 2005.
(8.83)	Amendment dated August 15, 2007 to Services Agreement between PIMCO Variable
	Insurance Trust, ING Life Insurance and Annuity Company and ReliaStar Life
	Insurance Company dated as of May 1, 2004 •Incorporated by reference to Post-
	Effective Amendment No. 51 to Registration Statement on Form N-4 (File No. 333-
	01107), as filed on May 23, 2008.
(8.84)	Services Agreement effective as of May 1, 2004 between Pacific Investment
	Management Company LLC (“PIMCO”), ING Life Insurance and Annuity Company
	and ReliaStar Life Insurance Company •Incorporated by reference to Post-Effective
	Amendment No. 38 to Registration Statement on Form N-4 (File No. 333-01107), as

	filed on February 11, 2005.
(8.85)	First Amendment dated August 15, 2007 to Services Agreement between Pacific
	Investment Management Company LLC (“PIMCO”), ING Life Insurance and Annuity
	Company, ReliaStar Life Insurance Company and Allianz Global Investors
	Distributors LLC effective as of May 1, 2004 •Incorporated by reference to Post-
	Effective Amendment No. 51 to Registration Statement on Form N-4 (File No. 333-
	01107), as filed on May 23, 2008.
(8.86)	Rule 22c-2 Agreement dated no later than April 16, 2007, is effective as of the 16th
	day of October, 2007 between Allianz Global Investors Distributors 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 by reference to Pre-
	Effective Amendment No. 1 to Registration Statement on Form N-4 (File No. 333-
	139695), as filed on July 6, 2007.
(8.87)	Participation Agreement made and entered into as of July 1, 2001 by and among
	Pioneer Variable Contracts Trust, Aetna Life Insurance and Annuity Company,
	Pioneer Investment Management, Inc. and Pioneer Funds Distributor, Inc. •
	Incorporated by reference to Post-Effective Amendment No. 27 to Registration
	Statement on Form N-4 (File No. 333-01107), as filed on October 26, 2001.
(8.88)	Amendment No. 1 is made and entered into as of May 1, 2004 to Participation
	Agreement between Pioneer Variable Contracts Trust and ING Life Insurance and
	Annuity Company f/k/a Aetna Life Insurance and Annuity Company, Pioneer
	Investment Management, Inc. and Pioneer Funds Distributor, Inc. dated July 1, 2001
	•Incorporated by reference to Post-Effective Amendment No. 40 to Registration
	Statement on Form N-4 (File No. 033-75962), as filed on April 13, 2005.
(8.89)	Amendment No. 2 is made and entered into as of August 15, 2007 to Participation
	Agreement between Pioneer Variable Contracts Trust, ING Life Insurance and
	Annuity Company, ReliaStar Life Insurance Company, ReliaStar Life Insurance
	Company of New York, Pioneer Investment Management, Inc. and Pioneer Funds
	Distributor, Inc. made and entered into as of July 1, 2001 and as amended on May 1,
	2004 •Incorporated 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.
(8.90)	Rule 22c-2 Agreement dated March 1, 2007 and is effective as of October 16, 2007
	between Pioneer Investment Management Shareholder Services, 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 by reference to Post-
	Effective Amendment No. 50 to Registration Statement on Form N-4 (File No. 033-
	75962), as filed on June 15, 2007.
(8.91)	Fund Participation Agreement effective as of May 1, 2004 between Wanger Advisors
	Trust, Columbia Wanger Asset Management, LP, ING Life Insurance and Annuity

	Company, and ReliaStar Life Insurance Company •Incorporated by reference to
	Post-Effective Amendment No. 38 to Registration Statement on Form N-4 (File No.
	333-01107), as filed on February 11, 2005.
(8.92)	Service Agreement with Investment Adviser effective as of May 1, 2004 between
	Columbia Wanger Asset Management, LP, ING Life Insurance and Annuity
	Company, ING Insurance Company of America, and ReliaStar Life Insurance
	Company •Incorporated by reference to Post-Effective Amendment No. 38 to
	Registration Statement on Form N-4 (File No. 333-01107), as filed on February 11,
	2005.
(8.93)	Rule 22c-2 Agreement dated April 16, 2007 and is effective as of October 16, 2007
	among Columbia Management Services, 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 Life Insurance Company and Systematized Benefits
	Administrators Inc. •Incorporated by reference to Post-Effective Amendment No. 3
	to Registration Statement on Form N-4 (File No. 333-134760), as filed on July 27,
	2007.
(9)	Opinion and Consent of Counsel
(10)	Consent of Independent Registered Public Accounting Firm
(11)	Not applicable
(12)	Not applicable
(13.1)	Powers of Attorney •Incorporated by reference to Post-Effective Amendment No. 41
	to Registration Statement on Form N-4 (File No. 033-75988), as filed on April 9,
	2008.
(13.2)	Authorization for Signatures • Incorporated by reference to Post-Effective
	Amendment No. 5 to Registration Statement on Form N-4 (File No. 033-75986), as
	filed on April 12, 1996.

Item 25. Directors and Officers of the Depositor*
Name and Principal	Positions and Offices with
Business Address	Depositor
Richard T. Mason1	President
Thomas J. McInerney1	Director and Chairman
Kathleen A. Murphy1	Director
Catherine H. Smith1	Director and Senior Vice President
Bridget M. Healy2	Director
Robert G. Leary2	Director
David A. Wheat3	Director, Executive Vice President and Chief
	Financial Officer
Steven T. Pierson3	Senior Vice President and Chief Accounting Officer
Sue A. Collins1	Senior Vice President and Chief Actuary
Boyd G. Combs3	Senior Vice President, Tax
Valerie G. Brown3	Senior Vice President
Brian D. Comer1	Senior Vice President
Daniel H. Hanlon1	Senior Vice President
Shaun P. Mathews4	Senior Vice President
David S. Pendergrass3	Senior Vice President and Treasurer
Stephen J. Preston5	Senior Vice President
Harry N. Stout5	Senior Vice President
Louis E Bachetti	Vice President
581 Main Street, 4th Fl.
Woodbridge, NJ 07095
Pamela Mulvey Barcia1	Vice President
Ronald R. Barhorst1	Vice President

Bradley E. Barks3	Vice President
M. Bishop Bastien	Vice President
980 Ninth Street
Sacramento, CA 95814
Jeoffrey A. Block6	Vice President
Dianne Bogoian1	Vice President
Mary A. Broesch5	Vice President and Actuary
Kevin P. Brown1	Vice President
Robert P. Browne3	Vice President, Investments
Anthony V. Camp1	Vice President
Kevin L. Christensen6	Vice President
Nancy D. Clifford1	Vice President
Monte J. Combe7	Vice President
Patricia M. Corbett6	Vice President
Kimberly Curley7	Vice President and Actuary
Karen Czizik7	Vice President
William Delahanty3	Vice President
J. Randolph Dobo7	Vice President
Michael C. Eldredge1	Vice President
Joseph Elmy3	Vice President, Tax
Patricia L. Engelhardt1	Vice President
William A. Evans4	Vice President
Ronald E. Falkner1	Vice President, Corporate Real Estate
John P. Foley3	Vice President, Investments
Molly A. Garrett1	Vice President
Robert A. Garrey1	Vice President

Lisa S. Gilarde1	Vice President
Saskia M. Goedhart1	Vice President
Brian K. Haendiges1	Vice President
Terry D. Harrell	Vice President
7695 N. High Street
Columbus, OH 43235
Steven J. Haun6	Vice President
June P. Howard3	Vice President
Mark Jackowitz	Vice President
22 Century Hill Drive, Suite 101
Latham, NY 12110
William S. Jasien	Vice President
12701 Fair Lakes Circle, Ste. 470
Fairfax, VA 22033
David A. Kelsey1	Vice President
Kenneth E. Lacy3	Vice President
Richard K. Lau5	Vice President and Actuary
William H. Leslie, IV1	Vice President
Frederick C. Litow3	Vice President
Laurie A. Lombardo1	Vice President
William L. Lowe1	Vice President
Alan S. Lurty5	Vice President
Christopher P. Lyons3	Vice President, Investments
Gilbert E. Mathis3	Vice President, Investments
Gregory R. Michaud3	Vice President, Investments
Gregory J. Miller1	Vice President
Paul L. Mistretta3	Vice President

Maurice M. Moore3	Vice President, Investments
Brian J. Murphy1	Vice President
Michael J. Murphy5	Vice President
Todd E. Nevenhoven6	Vice President
Michael J. Pise1	Vice President
Deborah J. Prickett6	Vice President
Srinivas D. Reddy1	Vice President
Robert A. Richard1	Vice President
Linda E. Senker5	Vice President, Compliance
Spencer T. Shell3	Vice President, Assistant Treasurer and Assistant
	Secretary
Frank W. Snodgrass	Vice President
9020 Overlook Blvd.
Brentwood, TN 37027
Libby J. Soong1	Vice President and Chief Compliance Officer
Christina M. Starks	Vice President
2000 21st Avenue NW
Minot, North Dakota 58703
Carl Steinhilber1	Vice President
Sandra L. Stokley6	Vice President
Alice Su5	Vice President and Actuary
Lisa A. Thomas1	Vice President and Appointed Actuary
Eugene M. Trovato1	Vice President
Mary A. Tuttle7	Vice President
William J. Wagner7	Vice President
Kurt W. Wassenar3	Vice President, Investments
Christopher R. Welp6	Vice President

Michellen A. Wildin7	Vice President
Matthew L. Condos1	Actuary
Scott N. Shepherd1	Actuary
Joy M. Benner8	Secretary
Edward Attarian5	Assistant Secretary
Jane A. Boyle1	Assistant Secretary
Diana R. Cavender8	Assistant Secretary
Maria C. Foster8	Assistant Secretary
Linda H. Freitag3	Assistant Secretary
Daniel F. Hinkel3	Assistant Secretary
Joseph D. Horan3	Assistant Secretary
Megan A. Huddleston1	Assistant Secretary
Rita J. Kummer3	Assistant Secretary
Susan A. Masse1	Assistant Secretary
Terri W. Maxwell3	Assistant Secretary
James M. May, III3	Assistant Secretary
Melissa A. O’Donnell8	Assistant Secretary
Randall K. Price7	Assistant Secretary
Patricia M. Smith1	Assistant Secretary
John F. Todd1	Assistant Secretary
Susan M. Vega8	Assistant Secretary
Diane I. Yell	Assistant Secretary
100 Washington Square
Minneapolis, MN 55401
Glenn A. Black3	Tax Officer

Terry L. Owens3	Tax Officer
James H. Taylor3	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.
2	The principal business address of these directors is 230 Park Avenue, New York, New York 10169.
3	The principal business address of these directors and these officers is 5780 Powers Ferry Road, N.W., Atlanta, Georgia 30327.
4	The principal business address of these officers is 10 State House Square, Hartford, Connecticut 06103.
5	The principal business address of these officers is 1475 Dunwoody Drive, West Chester, Pennsylvania 19380-1478.
6	The principal business address of these officers is 909 Locust Street, Des Moines, Iowa 50309.
7	The principal business address of these officers is 1290 Broadway, Denver, Colorado 80203.
8	The principal business address of these officers is 20 Washington Avenue South, Minneapolis, Minnesota 55401.

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. 10 to Registration
Statement on Form N-4 for Variable Annuity Account C of ING Life Insurance and Annuity
Company (File No. 333-105479), as filed with the Securities and Exchange Commission on
April 11, 2008.

Item 27. Number of Contract Owners

As of May 30, 2008, there were 636,992 individuals holding interests in variable annuity
contracts funded through Variable Annuity Account C 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 is or was a director of the corporation. Consistent with
the statute, ING America Insurance Holdings, Inc. maintains a Professional Liability umbrella
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 interest of 50% or more. This would encompass the principal underwriter as well as
the depositor. Additionally, the parent company of ING America Insurance Holdings, Inc., ING
Groep N.V., maintains an excess umbrella cover with limits in excess of $125,000,000. The
policy provides 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 Annuity
Account B 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	Positions and Offices with
Business Address	Principal Underwriter
Ronald R. Barhorst	Director and President
4225 Executive Square
La Jolla, California 92037
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
Daniel H. Hanlon1	Senior Vice President
William Jasien3	Senior Vice President
Louis E. Bachetti	Senior Vice President
581 Main Street, 4th Fl.
Woodbridge, NJ 07095
Pamela Mulvey Barcia1	Vice President
Robert H. Barley1	Vice President

M. Bishop Bastien	Vice President
980 Ninth Street
Sacramento, CA 95814
Nancy B. Bocella1	Vice President
Dianne Bogoian1	Vice President
J. Robert Bolchoz	Vice President
Columbia, South Carolina
David A. Brounley1	Vice President
Anthony V. Camp, Jr.1	Vice President
Mary Kathleen Carey-Reid1	Vice President
Nancy D. Clifford1	Vice President
William P. Elmslie	Vice President
New York, New York
Joseph J. Elmy2	Vice President, Tax
Brian K. Haendiges1	Vice President
Bernard P. Heffernon	Vice President
10740 Nall Ave., Ste. 120
Overland Park, KS 66211
David Kelsey1	Vice President
Christina Lareau1	Vice President
George D. Lessner	Vice President
Richardson, Texas
Katherine E. Lewis	Vice President
2675 N Mayfair Road, Ste. 501
Milwaukee, WI 53226
David J. Linney	Vice President
2900 N. Loop W., Ste. 180
Houston, TX 77092
Frederick C. Litow2	Vice President
Mark R. Luckinbill	Vice President
2841 Plaza Place, Ste. 210
Raleigh, NC 27612
Richard T. Mason1	Vice President

Scott T. Neeb	Vice President
4600 Ulster Street
Denver, CO 80237
David Pendergrass2	Vice President and Treasurer
Ethel Pippin1	Vice President
Michael J. Pise1	Vice President
Srinivas D. Reddy1	Vice President
Deborah Rubin3	Vice President
Todd Smiser	Vice President
Lisle, Illinois
Frank W. Snodgrass	Vice President
150 4th Ave., N., Ste. 410
Nashville, TN 37219
Marilyn S. Sponzo1	Vice President and Chief Compliance Officer
Christina M. Starks	Vice President
2000 21st Avenue NW
Minot, North Dakota 58703
S. Bradford Vaughan, Jr.	Vice President
601 Union St., Ste. 810
Seattle, WA 98101
Forrest R. Wilson	Vice President
2202 N. Westshore Blvd.
Tampa, Florida 33607
Judeen T. Wrinn1	Vice President
Nancy S. Stillman	Assistant Vice President
Richard E. G. Gelfand	Chief Financial Officer
1475 Dunwoody Drive
West Chester, PA 19380-1478
Joy M. Benner4	Secretary
Diana R. Cavender4	Assistant Secretary
Randall K. Price4	Assistant Secretary

Todd Smiser	Assistant Secretary
2525 Cabot Drive, Suite 100
Lisle, IL 60532
John F. Todd1	Assistant Secretary
Susan M. Vega4	Assistant Secretary
Glenn A. Black2	Tax Officer
Terry L. Owens2	Tax Officer
James H. Taylor2	Tax Officer

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 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.

(c) Compensation to Principal Underwriter during last fiscal year:
(1)	(2)	(3)	(4)	(5)
Name of	Net Underwriting	Compensation
Principal	Discounts and	on Redemption	Brokerage
Underwriter	Commissions	or Annuitization	Commissions	Compensation*
ING Financial				$44,267,199.63
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 C of ING Life Insurance and Annuity Company during 2007.

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.

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.
(d)	during the Guarantee Period, to mail notices to current shareholders promptly after the happening of significant events related to the guarantee issued by ING Life Insurance and Annuity Company (the “Guarantee”). These significant events include (i) the termination of the Guarantee; (ii) a default under the Guarantee that has a material adverse effect on a shareholder’s right to receive his or her guaranteed amount on the maturity date; (iii) the insolvency of ING Life Insurance and Annuity Company; or (iv) a reduction in the credit rating of ING Life Insurance and Annuity Company’s long- term debt as issued by Standard & Poor’s or Moody’s Investors Service, Inc. to BBB+ or lower or Baa1 or lower, respectively.

During the Guarantee Period, the Registrant hereby undertakes to include in the
prospectus which is a part of this registration statement on Form N-4, a space that an
applicant can check to request the most recent annual and/or quarterly report of ING
Life Insurance and Annuity Company.

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 C 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. 033-75988) and has duly caused this Post-Effective
Amendment to be signed on its behalf by the undersigned, thereunto duly authorized, in the Town of
Windsor, State of Connecticut, on the 27th day of June, 2008.

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

By:	ING LIFE INSURANCE AND ANNUITY
	COMPANY
	(Depositor)
By:	Richard T. Mason*
Richard T. Mason President (principal executive officer)

As required by the Securities Act of 1933, this Post-Effective Amendment No. 42 to the
Registration Statement has been signed by the following persons in the capacities and on the date
indicated.

Signature	Title	Date
Richard T. Mason*	President	)
Richard T. Mason	(principal executive officer)	)
		)
Thomas J. McInerney*	Director and Chairman	) June  27, 2008
Thomas J. McInerney		)
		)
Kathleen A. Murphy*	Director	)
Kathleen A. Murphy		)
		)
Catherine H. Smith*	Director and Senior Vice President	)
Catherine H. Smith		)
		)
Bridget M. Healy*	Director	)
Bridget M. Healy		)
		)
Robert G. Leary*	Director	)
Robert G. Leary		)
		)

David A. Wheat*	Director, Executive Vice President and Chief Financial	)
David A. Wheat	Officer	)
		)
Steven T. Pierson*	Senior Vice President and Chief Accounting Officer	)
Steven T. Pierson		)
By: /s/      Michael A. Pignatella
Michael A. Pignatella
*Attorney-in-Fact

	VARIABLE ANNUITY ACCOUNT C
	EXHIBIT INDEX
Exhibit No.	Exhibit
99-B.9	Opinion and Consent of Counsel
99-B.10	Consent of Independent Registered Public Accounting Firm