485BPOS

As filed with the Securities and Exchange		Registration No. 033-75988*
Commission on December 3, 2010		Registration No. 811-02513
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM N-4
Post-Effective Amendment No. 45 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) 580-2824
J. Neil McMurdie, Senior 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 30, 2010 are

incorporated into Parts A and B, respectively, of this Post-Effective Amendment No. 45 by

reference to Registrant’s filing under Rule 485(b) as filed on April 13, 2010 and under Rule

497(e) as filed on June 14, 2010, June 15, 2010 and September 21, 2010.

A supplement dated December 3, 2010 to the Prospectus is included in Part A of this Post-Effective Amendment No. 45.

ING Life Insurance and Annuity Company
and its
Variable Annuity Account C
ING Pension IRA
Supplement dated December 3, 2010 to the Contract Prospectus
dated April 30, 2010, as amended
The following information updates and amends certain information contained in your variable annuity Contract
Prospectus. Please read it carefully and keep it with your current Contract Prospectus for future reference.
Please Note: The following information only affects you if you currently invest or plan to
invest in a subaccount that corresponds to the funds referenced below.
Important Information Regarding Fund Changes
1	.	Effective August 31, 2010, the following fund changed from non-diversified to diversified:
		· ING Clarion Global Real Estate Portfolio
2	.	Effective January 4, 2011, the investment objective for the ING Thornburg Value Portfolio will change to
		“Seeks long-term capital appreciation, and secondarily current income.”
3	.	Effective after the close of business on or about January 21, 2011, the following fund name changes,
		subadviser changes, and investment objective changes will occur:
		The ING Oppenheimer Global Strategic Income Portfolio will:
		· Change its subadviser to ING Investment Management Co. (“ING IM”), under an interim-subadvisory
		agreement;
		· Change its name to ING Global Bond Portfolio; and
		· Change its investment objective to “Seeks to maximize total return through a combination of current
		income and capital appreciation.”
		Subject to shareholder approval, the ING Pioneer Equity Income Portfolio will:
		· Change its subadviser to ING Investment Management Co. (“ING IM”), as well as add ING Investment
		Management Advisors, B.V., and ING Investment Management Asia/Pacific (Hong Kong) Limited as
		subadvisers;
		· Change its name to ING Large Cap Value Portfolio; and
		· Change its investment objective to “Seeks long-term growth of capital and current income.”
		Accordingly, effective after the close of business on or about January 21, 2011, all references to ING
		Oppenheimer Global Strategic Income Portfolio and ING Pioneer Equity Income Portfolio in the Contract Prospectus are deleted and replaced with ING Global Bond Portfolio and, subject to shareholder approval of ING IM as the new subadviser, ING Large Cap Value Portfolio, respectively.
X.75988-10 D			Page 1 of 3	December 2010

4	.	Effective as of the dates noted above, the information for the ING Clarion Global Real Estate Portfolio, ING
		Oppenheimer Global Strategic Income Portfolio, ING Pioneer Equity Income Portfolio and ING Thornburg
		Value Portfolio appearing in the Contract Prospectus under Appendix IV - Description of Underlying Funds is
		deleted and replaced with the following:

Fund Name and
Investment Adviser/Subadviser	Investment Objective(s)
ING Investors Trust – ING Clarion Global Real	Seeks to provide investors with high total return,
Estate Portfolio	consisting of capital appreciation and current income.
Investment Adviser: ING Investments, LLC
Subadviser: ING Clarion Real Estate Securities
LLC
ING Partners, Inc. – ING Global Bond	Seeks to maximize total return through a combination of
Portfolio (formerly ING Oppenheimer Global	current income and capital appreciation.
Strategic Income Portfolio)
Investment Adviser: Directed Services LLC
Subadviser: ING Investment Management Co.
ING Investors Trust – ING Large Cap Value	Seeks long-term growth of capital and current income.
Portfolio (formerly ING Pioneer Equity Income
Portfolio)
Investment Adviser: Directed Services LLC
Subadvisers: ING Investment Management Co.,
ING Investment Management Advisors, B.V.,
and ING Investment Management Asia/Pacific
(Hong Kong) Limited
ING Partners, Inc. – ING Thornburg Value	Seeks long-term capital appreciation, and secondarily
Portfolio	current income.
Investment Adviser: Directed Services LLC
Subadviser: Thornburg Investment
Management, Inc.

Notice of Upcoming Fund Reorganizations

1	.	The Board of Trustees of ING Investors Trust and the Board of Directors of ING Partners, Inc. have approved a
		proposal to reorganize certain funds. Subject to shareholder approval, effective after the close of business on or
		about January 21, 2011, (the “Reorganization Date”) the following Disappearing Portfolios will reorganize into
		and become part of the following Surviving Portfolios:

Disappearing Portfolios	Surviving Portfolios
ING Legg Mason ClearBridge Aggressive Growth	ING Large Cap Growth Portfolio (Class I)
Portfolio (I Class)
ING Lord Abbett Growth and Income Portfolio	ING Large Cap Value Portfolio (formerly ING Pioneer
(Class I)	Equity Income Portfolio) (Class I)

X.75988-10 D Page 2 of 3 December 2010

Important Information about the Upcoming Fund Reorganizations

· Prior to the Reorganization Date, you may transfer amounts allocated to a subaccount that invests in a

Disappearing Portfolio to any other available subaccount or any available fixed interest option. See also the

Transfers Among Investment Options section of your Contract Prospectus for further information

about making transfers, including limits on transfers.

· On the Reorganization Date, your investment in a subaccount that invests in a Disappearing Portfolio will

automatically become an investment in the subaccount that invests in the corresponding Surviving Portfolio

with an equal total net asset value.

· You will not incur any fees or charges or any tax liability because of the reorganizations.

· Unless you provide us with alternative allocation instructions, all future allocations directed to the

subaccounts that invest in the Disappearing Portfolios after the Reorganization Date will be automatically

allocated to the subaccounts that invest in the corresponding Surviving Portfolios. You may give us

alternative allocation instructions at any time by contacting our Customer Service Center at:

ING

USFS Customer Service

Defined Contribution Administration

P.O. Box 990063

Hartford, CT 06199-0063

1-800-262-3862

· After the Reorganization Date, each Disappearing Portfolio will no longer exist and all references to them

in the Contract Prospectus will be replaced by the corresponding Surviving Portfolio.

2	.	As a consequence of the reorganization involving the ING Legg Mason ClearBridge Aggressive Growth
		Portfolio referenced above, effective on the Reorganization Date, Class I of the ING Large Cap Growth
		Portfolio will automatically be added to your contract as an investment option. Accordingly, effective after the
		close of business on or about January 21, 2011, the following information regarding the ING Large Cap Growth
		Portfolio is added to Appendix IV- Description of Underlying Funds in the Contract Prospectus.

Fund Name and
Investment Adviser/Subadviser	Investment Objective(s)
ING Investors Trust – ING Large Cap Growth	Seeks long-term capital growth.
Portfolio
Investment Adviser: Directed Services LLC
Subadviser: ING Investment Management Co.

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 will be no change to the hypothetical examples shown
		in the Contract Prospectus.

X.75988-10 D Page 3 of 3 December 2010

				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, 2009
			-	Statements of Operations for the year ended December 31, 2009
			-	Statements of Changes in Net Assets for the years ended December 31, 2009
				and 2008
			-	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,
				2009, 2008 and 2007
			-	Consolidated Balance Sheets as of December 31, 2009 and 2008
			-	Consolidated Statements of Changes in Shareholder’s Equity for the years
				ended December 31, 2009, 2008 and 2007
			-	Consolidated Statements of Cash Flows for the years ended December 31,
				2009, 2008 and 2007
			-	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. 30 to Registration Statement on Form N-4 (File No. 033-75988), as filed on December 30, 2003.
	(4.3	)		Variable Annuity Contract IRA-CDA-03(NY) ·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.
(4.4	)	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 October 1, 2007) 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 31, 2008.
(6.2	)	Amended and Restated By-Laws of ING Life Insurance and Annuity Company,
		effective October 1, 2007 ·Incorporated by reference to the ING Life Insurance and
		Annuity Company annual report on Form 10-K (File No. 033-23376), as filed on
		March 31, 2008.

(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	)	Amended and Restated Participation Agreement as of June 26, 2009 by and among
		ING Life Insurance and Annuity Company, Fidelity Distributors Corporation,
		Variable Insurance Products Fund, Variable Insurance Products Fund II, Variable
		Insurance Products Fund III, Variable Insurance Products Fund IV and Variable
		Insurance Products Fund V ·Incorporated by reference to Post-Effective Amendment
		No. 56 to Registration Statement on Form N-4 (File No. 333-01107), as filed on
		December 18, 2009.
(8.15	)	First Amendment as of June 26, 2009 to Participation Agreement as of June 26, 2009
		by and among ING Life Insurance and Annuity Company, Fidelity Distributors
		Corporation, Variable Insurance Products Fund, Variable Insurance Products Fund II,
		Variable Insurance Products Fund III, Variable Insurance Products Fund IV and
		Variable Insurance Products Fund V ·Incorporated by reference to Post-Effective
		Amendment No. 56 to Registration Statement on Form N-4 (File No. 333-01107), as
		filed on December 18, 2009.

(8.16	)	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.
(8.17	)	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.
(8.18	)	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.
(8.19	)	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.
(8.20	)	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.
(8.21	)	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.
(8.22	)	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.

(8.23	)	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.
(8.24	)	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.
(8.25	)	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.
(8.26	)	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.
(8.27	)	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.
(8.28	)	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.
(8.29	)	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.
(8.30	)	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.
(8.31	)	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.
(8.32	)	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.
(8.33	)	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.
(8.34	)	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.
(8.35	)	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.
(8.36	)	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.
(8.37	)	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.
(8.38	)	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.
(8.39	)	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.
(8.40	)	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.
(8.41	)	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.
(8.42	)	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.
(8.43	)	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.
(8.44	)	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.
(8.45	)	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.
(8.46	)	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.
(8.47	)	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.
(8.48	)	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.
(8.49	)	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.
(8.50	)	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.
(8.51	)	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.
(8.52	)	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.
(8.53	)	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.
(8.54	)	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.
(8.55	)	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.
(8.56	)	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.
(8.57	)	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.
(8.58	)	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.
(8.59	)	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.
(8.60	)	First Amendment dated April 30, 2009 and effective as of May 1, 2005 to Fund
		Participation Agreement effective as of July 20, 2001 among ING Life Insurance and
		Annuity Company (formerly Aetna Life Insurance and Annuity Company), Lord
		Abbett Series Fund, Inc. and Lord Abbett Distributor LLC ·Incorporated by reference
		to Post-Effective Amendment No. 56 to Registration Statement on Form N-4 (File No.
		333-01107), as filed on December 18, 2009.
(8.61	)	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.

(8.62	)	First Amendment dated April 30, 2009 and effective as of May 1, 2005 to Service
		Agreement effective as of July 20, 2001 between ING Life Insurance and Annuity
		Company (formerly Aetna Life Insurance and Annuity Company) and Lord Abbett
		Series Fund, Inc. ·Incorporated by reference to Post-Effective Amendment No. 56 to
		Registration Statement on Form N-4 (File No. 333-01107), as filed on December 18,
		2009.
(8.63	)	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.
(8.64	)	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.
(8.65	)	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.
(8.66	)	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.
(8.67	)	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.
(8.68	)	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.
(8.69	)	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.
(8.70	)	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.
(8.71	)	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.
(8.72	)	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.
(8.73	)	First 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.
(8.74	)	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.
(8.75	)	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.

(8.76	)	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.
(8.77	)	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.
(8.78	)	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.
(8.79	)	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.
(8.80	)	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.
(8.81	)	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.
(8.82	)	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.
(8.83	)	First Amendment dated May 7, 2007 to Fund Participation Agreement effective as of
		May 1, 2004 between Columbia Wanger Asset Management, LP, Wanger Advisors
		Trust, ING Life Insurance and Annuity Company and ReliaStar Life Insurance
		Company ·Incorporated by reference to Post-Effective Amendment No. 53 to
		Registration Statement on Form N-4 (File No. 333-01107), as filed on August 18,
		2008.
(8.84	)	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
(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
Catherine H. Smith1	President and Director
Thomas J. McInerney1	Director and Chairman
Donald W. Britton2	Director
Lynne R. Ford3	Director and Executive Vice President
Robert G. Leary3	Director
Michael S. Smith4	Director
Ewout L. Steenbergen3	Director, Executive Vice President and Chief
	Financial Officer
Steven T. Pierson2	Senior Vice President and Chief Accounting Officer
Boyd G. Combs2	Senior Vice President, Tax
Brian D. Comer1	Senior Vice President
Ralph R. Ferraro1	Senior Vice President
Mark B. Kaye4	Senior Vice President
Richard T. Mason1	Senior Vice President
Shaun P. Mathews5	Senior Vice President
Timothy T. Matson1	Senior Vice President
David S. Pendergrass2	Senior Vice President and Treasurer
Prakash Shimpi3	Senior Vice President
Carol Stern6	Vice President and Chief Compliance Officer
Joy M. Benner7	Secretary

*	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 this director and these officers is 5780 Powers Ferry Road,
	N.W., Atlanta, Georgia 30327.
3	The principal business address of these directors and this officer is 230 Park Avenue, New
	York, New York 10169.
4	The principal business address of this director and this officer is 1475 Dunwoody Drive,
	West Chester, Pennsylvania 19380-1478.
5	The principal business address of this officer is 10 State House Square, Hartford,
	Connecticut 06103.
6	The principal business address of this officer is 601 Thirteenth Street NW, Washington, DC
	20005.
7	The principal business address of this officer 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 28 in Pre-Effective Amendment No. 1 to the Registration Statement on Form N-6 for Security Life Separate Account L1 of Security Life of Denver Insurance Company (File No. 333-168047), as filed with the Securities and Exchange Commission on October 6, 2010.

Item 27. Number of Contract Owners

As of October 31, 2010, there were 635,282 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 t o a proceeding) when (1) a determination is made pursuant to Section 33-775 that the party seeking indemnification has met the standard of conduct set forth in Section 33-771 or (2) a court has determined that indemnification is appropriate pursuant to Section 33-774. Under Section 33-775, the determination of and the authorization for indemnification are made (a) by two or more disinterested directors, as defined in Section 33-770(3); (b) by special legal counsel; (c) by the shareholders; or (d) in the case of indemnification of an officer, agent or employee of the corporation, by the general counsel of the corporation or such other officer(s) as the board of directors may specify. Also, Section 33-772 with Section 33-776 provide that a corporation shall

indemnify an individual who was wholly successful on the merits or otherwise against reasonable expenses incurred by him in connection with a proceeding to which he was a party because he is or was a director, officer, employee, or agent of the corporation. Pursuant to Section 33-771(d), in the case of a proceeding by or in the right of the corporation or with respect to conduct for which the director, officer, agent or employee was adjudged liable on the basis that he received a financial benefit to which he was not entitled, indemnification is limited to reasonable expenses incurred in connection with the proceeding against the corporation to which the individual was named a party.

A corporation may procure indemnification insurance on behalf of an individual who is or was a director of the corporation. Consistent with the laws of the State of Connecticut, ING America Insurance Holdings, Inc. maintains Professional Liability and fidelity bond insurance policies issued by an international insurer. The policies cover ING America Insurance Holdings, Inc. and any company in which ING America Insurance Holdings, Inc. has a controlling financial interest of 50% or more. These policies include the principal underwriter, as well as the depositor and any/all assets under the care, custody and control of ING America Insurance Holdings, Inc. and/or its subsidiaries. The policies provide for the following types of coverage: errors and omissions/professional liability, employment practices liability and fidelity/crime.

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, NG 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 sep arate 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
Randall L. Ciccati1	Director
Brian D. Comer1	Director and Senior Vice President
William Wilcox1	Director and Chief Compliance Officer
Boyd G. Combs2	Senior Vice President, Tax
William Jasien3	Senior Vice President
M. Bishop Bastien	Vice President
980 Ninth Street
Sacramento, CA 95814
Nancy B. Boccella1	Vice President
Dianne C Bogoian1	Vice President
Anthony V. Camp, Jr.1	Vice President
Mary Kathleen Carey-Reid1	Vice President
Nancy D. Clifford1	Vice President
Chris Cokinis4	Vice President
William P. Elmslie	Vice President
New York, New York
Joseph J. Elmy2	Vice President, Tax

Name and Principal	Positions and Offices with
Business Address	Principal Underwriter
Bernard P. Heffernon	Vice President
10740 Nall Ave., Ste. 120
Overland Park, KS 66211
Mark E. Jackowitz	Vice President
22 Century Hill Dr., Ste. 101
Latham, NY 12110
Dave Kaherl1	Vice President
David Kelsey1	Vice President
Barbara J. Kesterson4	Vice President
Christina Lareau1	Vice President
George D. Lessner, Jr.	Vice President
Richardson, Texas
Katherine E. Lewis	Vice President
10700 West Research Dr., Ste. 190
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
Pamela L. Mulvey1	Vice President
Brian J. Murphy1	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

Name and Principal	Positions and Offices with
Business Address	Principal Underwriter
Spencer T. Shell2	Vice President and Assistant Treasurer
Frank W. Snodgrass	Vice President
9020 Overlook Blvd.
Brentwood, TN 37027
Christina M. Starks	Vice President
2000 21st Avenue NW
Minot, North Dakota 58703
Carl P. Steinhilber1	Vice President
Terran Titus1	Vice President
S. Bradford Vaughan, Jr.	Vice President
2510 Pike Street, Ste. 2510
Seattle, WA 98101
Judeen T. Wrinn1	Vice President
Nancy S. Stillman1	Assistant Vice President
Kristin H. Hultgren1	Chief Financial Officer
Joy M. Benner5	Secretary
John Cecere1	Assistant Secretary
Tina M. Nelson5	Assistant Secretary
Melissa A. O’Donnell5	Assistant Secretary
Randall K. Price5	Assistant Secretary
Susan M. Vega5	Assistant Secretary
Terry L. Owens2	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 909 Locust Street, Des Moines, Iowa
	50309.

5		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									$	44,259,566.54
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 2009.
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;
		(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; and

(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 que stion 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 3rd day of December, 2010.
	VARIABLE ANNUITY ACCOUNT C OF
	ING LIFE INSURANCE AND ANNUITY COMPANY
	(Registrant)
	By:	ING LIFE INSURANCE AND ANNUITY
		COMPANY
		(Depositor)
	By:	Catherine H. Smith*
		Catherine H. Smith
		President
		(principal executive officer)

As required by the Securities Act of 1933, this Post-Effective Amendment No. 45 to the
Registration Statement has been signed by the following persons in the capacities and on the date
indicated.
Signature	Title		Date
Catherine H. Smith*	President and Director	)
Catherine H. Smith	(principal executive officer)	)
		)
T. J. McInerney*	Director and Chairman	)	December
Thomas J. McInerney		)	3, 2010
		)
Donald Britton*	Director	)
Donald Britton		)
		)
Lynne R. Ford*	Director and Executive Vice President	)
Lynne R. Ford		)
		)
Robert G. Leary*	Director	)
Robert G. Leary		)
		)
Ewout  Steenbergen*	Director, Executive Vice President and Chief Financial	)
Ewout  Steenbergen	Officer	)
		)
Michael S. Smith*	Director	)
Michael S. Smith		)
		)

Steven T. Pierson*	Senior Vice President and Chief Accounting Officer	)
Steven T. Pierson		)
By: /s/ J. Neil McMurdie
J. Neil McMurdie
*Attorney-in-Fact

		VARIABLE ANNUITY ACCOUNT C
		EXHIBIT INDEX
Exhibit No.		Exhibit
24	(b)(9)	Opinion and Consent of Counsel	_______
24(b)	(10)	Consent of Independent Registered Public Accounting Firm	_______
24(b)	(13.1)	Powers of Attorney	_______

EX-24

Exhibit 24(b)(9)

AMERICAS
US Legal Services

J. Neil McMurdie
Senior Counsel
(860) 580-2824
Fax: (860) 580-4844
Neil.mcmurdie@us.ing.com

December 3, 2010

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. 45 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 811-2513

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

In connection with this opinion, I have reviewed the N-4 Registration, as amended to the date

hereof, and this Post-Effective Amendment No. 45. 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/ J. Neil McMurdie

J. Neil McMurdie

EX-24

Exhibit 24(b)(10) – Consent of Ernst and Young LLP, Independent Registered Public Accounting Firm

We consent to the reference to our firm under the caption “Experts” and to the use of our report dated March 31, 2010 (except for Note 2, as to which the date is April 5, 2010), with respect to the consolidated financial statements of ING Life Insurance and Annuity Company as of December 31, 2009 and 2008, and for each of the three years in the period ended December 31, 2009, and to the use of our report dated April 8, 2010, with respect to the statements of assets and liabilities of Variable Annuity Account C of ING Life Insurance and Annuity Company as of December 31, 2009, and the related statements of operations and changes in net assets for the periods disclosed in the financial statements, incorporated by reference in Post-Effective Amendment No. 45 to the Registration Statement (Form N-4, No. 033-75988) and related Prospectus and Statement of Additional Information of Variable Annuity Account C of ING Life Insurance and Annuity Company.

                                                                                                /s/ Ernst & Young LLP

Atlanta, Georgia

December 3, 2010

EX-24

Exhibit 24(b)(13.1)

POWER OF ATTORNEY

Pursuant to Item 601(b)(24) of Regulation SK and Rule 462(b) of the Securities Act of 1933
The undersigned, on behalf of the company set forth below, hereby constitutes and appoints the individuals set forth
below and each of them individually as my true and lawful attorneys with full power to them and each of them to sign
for me and in my name and in the capacity indicated below any and all amendments to the Registration Statements listed
below filed with the Securities and Exchange Commission under the Securities Act of 1933 and the Investment
Company Act of 1940 and any documentation, including Form N-8F, necessary to deregister any such registrations or to
deregister any of the entities (including any issuing separate accounts) associated with the issuance of any such
registrations.
COMPANY: ING Life Insurance and Annuity Company
INDIVIDUALS WITH POWER OF ATTORNEY:  John S. (Scott) Kreighbaum, J. Neil McMurdie, Nicholas
Morinigo and Michael A. Pignatella
REGISTRATION STATEMENTS FILED UNDER THE SECURITIES ACT OF 1933:
033-34370	033-75988	033-79122	333-105479	333-130827	333-162140
033-61897	033-75992	033-81216	333-109622	333-130833	333-162420
033-64277	033-75996	333-01107	333-109860	333-133157	333-162593
033-75248	033-75998	333-09515	333-129091	333-133158
033-75962	033-76002	333-27337	333-130822	333-134760
033-75974	033-76004	333-56297	333-130825	333-153730
033-75980	033-76018	333-72079	333-130826	333-158492
REGISTRATION STATEMENTS FILED UNDER THE INVESTMENT COMPANY ACT OF 1940:
811-02512	811-02513	811-04536	811-05906	811-08582
I hereby ratify and confirm on this 5th day of February, 2010, my signature as it may be signed by my said attorneys to
any such registration statements and any and all amendments thereto.
		Signature
		/s/ Catherine H. Smith
		Catherine H. Smith, President and Director

POWER OF ATTORNEY

Pursuant to Item 601(b)(24) of Regulation SK and Rule 462(b) of the Securities Act of 1933
The undersigned, on behalf of the company set forth below, hereby constitutes and appoints the individuals set forth
below and each of them individually as my true and lawful attorneys with full power to them and each of them to sign
for me and in my name and in the capacity indicated below any and all amendments to the Registration Statements listed
below filed with the Securities and Exchange Commission under the Securities Act of 1933 and the Investment
Company Act of 1940 and any documentation, including Form N-8F, necessary to deregister any such registrations or to
deregister any of the entities (including any issuing separate accounts) associated with the issuance of any such
registrations.
COMPANY: ING Life Insurance and Annuity Company
INDIVIDUALS WITH POWER OF ATTORNEY:   John S. (Scott) Kreighbaum, J. Neil McMurdie, Nicholas
Morinigo and Michael A. Pignatella
REGISTRATION STATEMENTS FILED UNDER THE SECURITIES ACT OF 1933:
033-34370	033-75988	033-79122	333-105479	333-130827	333-162140
033-61897	033-75992	033-81216	333-109622	333-130833	333-162420
033-64277	033-75996	333-01107	333-109860	333-133157	333-162593
033-75248	033-75998	333-09515	333-129091	333-133158
033-75962	033-76002	333-27337	333-130822	333-134760
033-75974	033-76004	333-56297	333-130825	333-153730
033-75980	033-76018	333-72079	333-130826	333-158492
REGISTRATION STATEMENTS FILED UNDER THE INVESTMENT COMPANY ACT OF 1940:
811-02512	811-02513	811-04536	811-05906	811-08582
I hereby ratify and confirm on this 29th day of January, 2010, my signature as it may be signed by my said attorneys to
any such registration statements and any and all amendments thereto.
		Signature
		/s/ T. J. McInerney
		Thomas J. McInerney, Director and Chairman

POWER OF ATTORNEY

Pursuant to Item 601(b)(24) of Regulation SK and Rule 462(b) of the Securities Act of 1933
The undersigned, on behalf of the company set forth below, hereby constitutes and appoints the
individuals set forth below and each of them individually as my true and lawful attorneys with full
power to them and each of them to sign for me and in my name and in the capacity indicated below
any and all amendments to the Registration Statements listed below filed with the Securities and
Exchange Commission under the Securities Act of 1933 and the Investment Company Act of 1940 and
any documentation, including Form N-8F, necessary to deregister any such registrations or to
deregister any of the entities (including any issuing separate accounts) associated with the issuance of
any such registrations.
COMPANY: ING Life Insurance and Annuity Company
INDIVIDUALS WITH POWER OF ATTORNEY: John S. (Scott) Kreighbaum, J. Neil McMurdie,
Nicholas Morinigo and Michael A. Pignatella
REGISTRATION STATEMENTS FILED UNDER THE SECURITIES ACT OF 1933:
033-34370	033-75988	033-79122	333-105479	333-130827	333-162140
033-61897	033-75992	033-81216	333-109622	333-130833	333-162420
033-64277	033-75996	333-01107	333-109860	333-133157	333-162593
033-75248	033-75998	333-09515	333-129091	333-133158
033-75962	033-76002	333-27337	333-130822	333-134760
033-75974	033-76004	333-56297	333-130825	333-153730
033-75980	033-76018	333-72079	333-130826	333-158492
REGISTRATION STATEMENTS FILED UNDER THE INVESTMENT COMPANY ACT OF
1940:
811-02512	811-02513	811-04536	811-05906	811-08582
I hereby ratify and confirm on this 3rd day of February, 2010, my signature as it may be signed by my
said attorneys to any such registration statements and any and all amendments thereto.
		Signature
		/s/ Ewout Steenbergen
Ewout Steenbergen, Director, Executive Vice President and Chief Financial Officer
State of New York
County of New York
On the 3rd day of February in the year 2010, before me, the undersigned, personally appeared Ewout Steenbergen,
personally known to me or proved to me on the basis of satisfactory evidence to be the individual whose name is subscribed
to the within instrument and acknowledged to me that he executed the same in his capacity, and that by his signature on the
instrument, the individual, or the person upon behalf of which the individual acted, executed the instrument.
		Helen M. Scheuer
/s/ Helen M. Scheuer		Notary Public, State of New York
Notary Public		No. 01SC352985
		Qualified in New York County
		Commission Expires 4-30-2011

CAUTION TO THE PRINCIPAL: Your Power of Attorney is an important document. As the
“principal,” you give the person whom you choose (your “agent”) authority to spend your money and
sell or dispose of your property during your lifetime without telling you. You do not lose your
authority to act even though you have given your agent similar authority.

When your agent exercises this authority, he or she must act according to any instructions you have
provided or, where there are no specific instructions, in your best interest. “Important Information for
the Agent” at the end of this document describes your agent’s responsibilities.

Your agent can act on your behalf only after signing the Power of Attorney before a notary public.

You can request information from your agent at any time. If you are revoking a prior Power of
Attorney by executing this Power of Attorney, you should provide written notice of the revocation to
your prior agent(s) and to the financial institutions where your accounts are located.

You can revoke or terminate your Power of Attorney at any time for any reason as long as you are of
sound mind. If you are no longer of sound mind, a court can remove an agent for acting improperly.

Your agent cannot make health care decisions for you. You may execute a “Health Care Proxy” to do
this.

The law governing Powers of Attorney is contained in the New York General Obligations Law, Article
5, Title 15. This law is available at a law library, or online through the New York State Senate or
Assembly websites, www.senate.state.ny.us or www.assembly.state.ny.us.

If there is anything about this document that you do not understand, you should ask a lawyer of your
own choosing to explain it to you.

Signature of Agents:
	State of Pennsylvania
/s/ John S. Kreighbaum	County of Chester
John S. (Scott ) Kreighbaum
	On this, the 19th day of February, 2010, before me Michael T.
	Zelinsky, the undersigned officer, personally appeared John S.
Commonwealth of Pennsylvania	(Scott) Kreighbaum, known to me (or satisfactorily proven) to be
Notarial Seal	the person whose name is subscribed as attorney in fact for Ewout
Michael T. Zelinsky, Notary Public	Steenbergen, and acknowledged that he executed the same as the act
West Whiteland Twp., Chester County	of his principal for the purposes therein contained.
My Commission Expires Jan. 31, 2012
/s/ Michael T. Zelinsky
	Notary Public
	State of Pennsylvania
/s/ Nicholas Morinigo	County of Chester
Nicholas Morinigo
	On this, the 19th day of February, 2010, before me Michael T.
	Zelinsky, the undersigned officer, personally appeared Nicholas
Commonwealth of Pennsylvania	Morinigo, known to me (or satisfactorily proven) to be the person
Notarial Seal	whose name is subscribed as attorney in fact for Ewout
Michael T. Zelinsky, Notary Public	Steenbergen, and acknowledged that he executed the same as the act
West Whiteland Twp., Chester County	of his principal for the purposes therein contained.
My Commission Expires Jan. 31, 2012
/s/ Michael T. Zelinsky
	Notary Public
	State of Connecticut
/s/ J. Neil McMurdie	County of Hartford Town of Windsor
J. Neil McMurdie
	The foregoing instrument was executed and acknowledged before
	me this 19th day of February, 2010, by J. Neil McMurdie, as
Nicole L. Molleur	attorney in fact on behalf of Ewout Steenbergen.
Notary Public Within and for
The State of Connecticut	/s/ Nicole L. Molleur
My commission expires: Nov. 30, 2014	Notary Public
	State of Connecticut
/s/ Michael A. Pignatella	County of Hartford Town of Windsor
Michael A. Pignatella
	The foregoing instrument was executed and acknowledged before
	me this 19th day of February, 2010, by Michael A. Pignatella, as
Nicole L. Molleur	attorney in fact on behalf of Ewout Steenbergen.
Notary Public Within and for
The State of Connecticut	/s/ Nicole L. Molleur
My commission expires: Nov. 30, 2014	Notary Public

IMPORTANT INFORMATION FOR THE AGENT:

When you accept the authority granted under this Power of Attorney, a special legal relationship is
created between you and the principal. This relationship imposes on you legal responsibilities that
continue until you resign or the Power of Attorney is terminated or revoked. You must:

(1) act according to any instructions from the principal, or, where there are no instructions, in the
principal’s best interest;

(2) avoid conflicts that would impair your ability to act in the principal’s best interest;

(3) keep the principal’s property separate and distinct from any assets you own or control, unless
otherwise permitted by law;

(4) keep a record of all receipts, payments, and transactions conducted for the principal; and

(5) disclose your identity as an agent whenever you act for the principal by writing or printing the
principal’s name and signing your own name as “agent” in either of the following manner: (Principal’s
Name) by (Your Signature) as Agent, or (your signature as Agent for (Principal’s Name).

You may not use the principal’s assets to benefit yourself or give major gifts to yourself or anyone else
unless the principal has specifically granted you that authority in this Power of Attorney or in a
Statutory Major Gifts Rider attached to this Power of Attorney. If you have that authority, you must act
according to any instructions of the principal or, where there are no such instructions, in the principal’s
best interest.; You may resign by giving written notice to the principal and to any co-agent, successor
agent, monitor if one has been named in this document, or the principal’s guardian if one has been
appointed. If there is anything about this document or your responsibilities that you do not understand,
you should seek legal advice.

Liability of the agent:

The meaning of the authority given to you is defined in New York’s General Obligations Law, Article
5, Title 15. If it is found that you have violated the law or acted outside the authority granted to you in
the Power of Attorney, you may be liable under the law for your violation.

POWER OF ATTORNEY

Pursuant to Item 601(b)(24) of Regulation SK and Rule 462(b) of the Securities Act of 1933
The undersigned, on behalf of the company set forth below, hereby constitutes and appoints the individuals set forth
below and each of them individually as my true and lawful attorneys with full power to them and each of them to sign
for me and in my name and in the capacity indicated below any and all amendments to the Registration Statements listed
below filed with the Securities and Exchange Commission under the Securities Act of 1933 and the Investment
Company Act of 1940 and any documentation, including Form N-8F, necessary to deregister any such registrations or to
deregister any of the entities (including any issuing separate accounts) associated with the issuance of any such
registrations.
COMPANY: ING Life Insurance and Annuity Company
INDIVIDUALS WITH POWER OF ATTORNEY:   John S. (Scott) Kreighbaum, J. Neil McMurdie, Nicholas
Morinigo and Michael A. Pignatella
REGISTRATION STATEMENTS FILED UNDER THE SECURITIES ACT OF 1933:
033-34370	033-75988	033-79122	333-105479	333-130827	333-162140
033-61897	033-75992	033-81216	333-109622	333-130833	333-162420
033-64277	033-75996	333-01107	333-109860	333-133157	333-162593
033-75248	033-75998	333-09515	333-129091	333-133158
033-75962	033-76002	333-27337	333-130822	333-134760
033-75974	033-76004	333-56297	333-130825	333-153730
033-75980	033-76018	333-72079	333-130826	333-158492
REGISTRATION STATEMENTS FILED UNDER THE INVESTMENT COMPANY ACT OF 1940:
811-02512	811-02513	811-04536	811-05906	811-08582
I hereby ratify and confirm on this 8th day of February, 2010, my signature as it may be signed by my said attorneys to
any such registration statements and any and all amendments thereto.
		Signature
		/s/ Steven T. Pierson
	Steven T. Pierson, Senior Vice President and Chief Accounting Officer

POWER OF ATTORNEY

Pursuant to Item 601(b)(24) of Regulation SK and Rule 462(b) of the Securities Act of 1933
The undersigned, on behalf of the company set forth below, hereby constitutes and appoints the
individuals set forth below and each of them individually as my true and lawful attorneys with full
power to them and each of them to sign for me and in my name and in the capacity indicated below
any and all amendments to the Registration Statements listed below filed with the Securities and
Exchange Commission under the Securities Act of 1933 and the Investment Company Act of 1940 and
any documentation, including Form N-8F, necessary to deregister any such registrations or to
deregister any of the entities (including any issuing separate accounts) associated with the issuance of
any such registrations.
COMPANY: ING Life Insurance and Annuity Company
INDIVIDUALS WITH POWER OF ATTORNEY: John S. (Scott) Kreighbaum, J. Neil McMurdie,
Nicholas Morinigo and Michael A. Pignatella
REGISTRATION STATEMENTS FILED UNDER THE SECURITIES ACT OF 1933:
033-34370	033-75988	033-79122	333-105479	333-130827	333-162420
033-61897	033-75992	033-81216	333-109622	333-130833	333-162593
033-64277	033-75996	333-01107	333-109860	333-133157	333-166370
033-75248	033-75998	333-09515	333-129091	333-133158
033-75962	033-76002	333-27337	333-130822	333-134760
033-75974	033-76004	333-56297	333-130825	333-153730
033-75980	033-76018	333-72079	333-130826	333-158492
REGISTRATION STATEMENTS FILED UNDER THE INVESTMENT COMPANY ACT OF
1940:
811-02512	811-02513	811-04536	811-05906	811-08582
I hereby ratify and confirm on this 10th day of May, 2010, my signature as it may be signed by my
said attorneys to any such registration statements and any and all amendments thereto.
		Signature
		/s/ Lynne R. Ford
	Lynne R. Ford, Director and Executive Vice President
State of New York
County of New York
On the 10th day of May in the year 2010, before me, the undersigned, personally appeared Lynne R. Ford,
personally known to me or proved to me on the basis of satisfactory evidence to be the individual whose name is
subscribed to the within instrument and acknowledged to me that she executed the same in her capacity, and that
by her signature on the instrument, the individual, or the person upon behalf of which the individual acted,
executed the instrument.
_/s/ Helen M. Scheuer_______		Helen M. Scheuer
Notary Public		Notary Public, State of New York
		No. 01SC352985
		Qualified in New York County
		Commission Expires 4-30-2011

CAUTION TO THE PRINCIPAL: Your Power of Attorney is an important document. As the
“principal,” you give the person whom you choose (your “agent”) authority to spend your money and
sell or dispose of your property during your lifetime without telling you. You do not lose your
authority to act even though you have given your agent similar authority.

When your agent exercises this authority, he or she must act according to any instructions you have
provided or, where there are no specific instructions, in your best interest. “Important Information for
the Agent” at the end of this document describes your agent’s responsibilities.

Your agent can act on your behalf only after signing the Power of Attorney before a notary public.

You can request information from your agent at any time. If you are revoking a prior Power of
Attorney by executing this Power of Attorney, you should provide written notice of the revocation to
your prior agent(s) and to the financial institutions where your accounts are located.

You can revoke or terminate your Power of Attorney at any time for any reason as long as you are of
sound mind. If you are no longer of sound mind, a court can remove an agent for acting improperly.

Your agent cannot make health care decisions for you. You may execute a “Health Care Proxy” to do
this.

The law governing Powers of Attorney is contained in the New York General Obligations Law, Article
5, Title 15. This law is available at a law library, or online through the New York State Senate or
Assembly websites, www.senate.state.ny.us or www.assembly.state.ny.us.

If there is anything about this document that you do not understand, you should ask a lawyer of your
own choosing to explain it to you.

Signature of Agents:
	State of Pennsylvania
/s/ John S. Kreighbaum	County of Chester
John S. (Scott ) Kreighbaum
	On this, the 10th day of May, 2010, before me Michael T. Zelinsky,
	the undersigned officer, personally appeared John S. (Scott)
	Kreighbaum, known to me (or satisfactorily proven) to be the
	person whose name is subscribed as attorney in fact for
Commonwealth of Pennsylvania	Lynne R. Ford, and acknowledged that he executed the same as the
Notarial Seal	act of his principal for the purposes therein contained.
Michael T. Zelinsky, Notary Public
West Whiteland Twp., Chester County	/s/ Michael T. Zelinsky
My Commission Expires Jan. 31, 2012	Notary Public
	State of Pennsylvania
/s/ Nicholas Morinigo	County of Chester
Nicholas Morinigo
	On this, the 10th day of May, 2010, before me Michael T. Zelinsky,
	the undersigned officer, personally appeared Nicholas Morinigo,
	known to me (or satisfactorily proven) to be the person whose name
	is subscribed as attorney in fact for Lynne R. Ford, and
Commonwealth of Pennsylvania	acknowledged that he executed the same as the act of his principal
Notarial Seal	for the purposes therein contained.
Michael T. Zelinsky, Notary Public
West Whiteland Twp., Chester County	/s/ Michael T. Zelinsky
My Commission Expires Jan. 31, 2012	Notary Public
	State of Connecticut
/s/ J. Neil McMurdie	County of Hartford Town of Windsor
J. Neil McMurdie
	The foregoing instrument was executed and acknowledged before
	me this 17th day of May, 2010, by J. Neil McMurdie, as attorney in
Nicole L. Molleur	fact on behalf of Lynne R. Ford.
Notary Public Within and for
The State of Connecticut	/s/ Nicole Molleur
My commission expires: Nov. 30, 2014	Notary Public
	State of Connecticut
/s/ Michael A. Pignatella	County of Hartford Town of Windsor
Michael A. Pignatella
	The foregoing instrument was executed and acknowledged before
	me this 17th day of May, 2010, by Michael A. Pignatella, as
Nicole L. Molleur	attorney in fact on behalf of Lynne R. Ford.
Notary Public Within and for
The State of Connecticut	/s/ Nicole Molleur
My commission expires: Nov. 30, 2014	Notary Public

IMPORTANT INFORMATION FOR THE AGENT:

When you accept the authority granted under this Power of Attorney, a special legal relationship is
created between you and the principal. This relationship imposes on you legal responsibilities that
continue until you resign or the Power of Attorney is terminated or revoked. You must:

(1) act according to any instructions from the principal, or, where there are no instructions, in the
principal’s best interest;

(2) avoid conflicts that would impair your ability to act in the principal’s best interest;

(3) keep the principal’s property separate and distinct from any assets you own or control, unless
otherwise permitted by law;

(4) keep a record of all receipts, payments, and transactions conducted for the principal; and

(5) disclose your identity as an agent whenever you act for the principal by writing or printing the
principal’s name and signing your own name as “agent” in either of the following manner: (Principal’s
Name) by (Your Signature) as Agent, or (your signature as Agent for (Principal’s Name).

You may not use the principal’s assets to benefit yourself or give major gifts to yourself or anyone else
unless the principal has specifically granted you that authority in this Power of Attorney or in a
Statutory Major Gifts Rider attached to this Power of Attorney. If you have that authority, you must act
according to any instructions of the principal or, where there are no such instructions, in the principal’s
best interest.; You may resign by giving written notice to the principal and to any co-agent, successor
agent, monitor if one has been named in this document, or the principal’s guardian if one has been
appointed. If there is anything about this document or your responsibilities that you do not understand,
you should seek legal advice.

Liability of the agent:

The meaning of the authority given to you is defined in New York’s General Obligations Law, Article
5, Title 15. If it is found that you have violated the law or acted outside the authority granted to you in
the Power of Attorney, you may be liable under the law for your violation.

POWER OF ATTORNEY

Pursuant to Item 601(b)(24) of Regulation SK and Rule 462(b) of the Securities Act of 1933
The undersigned, on behalf of the company set forth below, hereby constitutes and appoints the individuals set forth
below and each of them individually as my true and lawful attorneys with full power to them and each of them to sign
for me and in my name and in the capacity indicated below any and all amendments to the Registration Statements listed
below filed with the Securities and Exchange Commission under the Securities Act of 1933 and the Investment
Company Act of 1940 and any documentation, including Form N-8F, necessary to deregister any such registrations or to
deregister any of the entities (including any issuing separate accounts) associated with the issuance of any such
registrations.
COMPANY: ING Life Insurance and Annuity Company
INDIVIDUALS WITH POWER OF ATTORNEY:   John S. (Scott) Kreighbaum, J. Neil McMurdie, Nicholas
Morinigo and Michael A. Pignatella
REGISTRATION STATEMENTS FILED UNDER THE SECURITIES ACT OF 1933:
033-34370	033-75988	033-79122	333-105479	333-130827	333-162140
033-61897	033-75992	033-81216	333-109622	333-130833	333-162420
033-64277	033-75996	333-01107	333-109860	333-133157	333-162593
033-75248	033-75998	333-09515	333-129091	333-133158
033-75962	033-76002	333-27337	333-130822	333-134760
033-75974	033-76004	333-56297	333-130825	333-153730
033-75980	033-76018	333-72079	333-130826	333-158492
REGISTRATION STATEMENTS FILED UNDER THE INVESTMENT COMPANY ACT OF 1940:
811-02512	811-02513	811-04536	811-05906	811-08582
I hereby ratify and confirm on this 4th day of February, 2010, my signature as it may be signed by my said attorneys to
any such registration statements and any and all amendments thereto.
		Signature
		/s/ Donald Britton
		Donald Britton, Director

POWER OF ATTORNEY

Pursuant to Item 601(b)(24) of Regulation SK and Rule 462(b) of the Securities Act of 1933
The undersigned, on behalf of the company set forth below, hereby constitutes and appoints the
individuals set forth below and each of them individually as my true and lawful attorneys with full
power to them and each of them to sign for me and in my name and in the capacity indicated below
any and all amendments to the Registration Statements listed below filed with the Securities and
Exchange Commission under the Securities Act of 1933 and the Investment Company Act of 1940 and
any documentation, including Form N-8F, necessary to deregister any such registrations or to
deregister any of the entities (including any issuing separate accounts) associated with the issuance of
any such registrations.
COMPANY: ING Life Insurance and Annuity Company
INDIVIDUALS WITH POWER OF ATTORNEY: John S. (Scott) Kreighbaum, J. Neil McMurdie,
Nicholas Morinigo and Michael A. Pignatella
REGISTRATION STATEMENTS FILED UNDER THE SECURITIES ACT OF 1933:
033-34370	033-75988	033-79122	333-105479	333-130827	333-162140
033-61897	033-75992	033-81216	333-109622	333-130833	333-162420
033-64277	033-75996	333-01107	333-109860	333-133157	333-162593
033-75248	033-75998	333-09515	333-129091	333-133158
033-75962	033-76002	333-27337	333-130822	333-134760
033-75974	033-76004	333-56297	333-130825	333-153730
033-75980	033-76018	333-72079	333-130826	333-158492
REGISTRATION STATEMENTS FILED UNDER THE INVESTMENT COMPANY ACT OF
1940:
811-02512	811-02513	811-04536	811-05906	811-08582
I hereby ratify and confirm on this 16th day of February, 2010, my signature as it may be signed by my
said attorneys to any such registration statements and any and all amendments thereto.
		Signature
		/s/ Robert G. Leary
		Robert G. Leary, Director
State of New York
County of New York
On the 16th day of February in the year 2010, before me, the undersigned, personally appeared Robert G. Leary, personally
known to me or proved to me on the basis of satisfactory evidence to be the individual whose name is subscribed to the
within instrument and acknowledged to me that he executed the same in his capacity, and that by his signature on the
instrument, the individual, or the person upon behalf of which the individual acted, executed the instrument.
		Helen M. Scheuer
/s/ Helen M. Scheuer		Notary Public, State of New York
Notary Public		No. 01SC352985
		Qualified in New York County
		Commission Expires 4-30-2011

CAUTION TO THE PRINCIPAL: Your Power of Attorney is an important document. As the
“principal,” you give the person whom you choose (your “agent”) authority to spend your money and
sell or dispose of your property during your lifetime without telling you. You do not lose your
authority to act even though you have given your agent similar authority.

When your agent exercises this authority, he or she must act according to any instructions you have
provided or, where there are no specific instructions, in your best interest. “Important Information for
the Agent” at the end of this document describes your agent’s responsibilities.

Your agent can act on your behalf only after signing the Power of Attorney before a notary public.

You can request information from your agent at any time. If you are revoking a prior Power of
Attorney by executing this Power of Attorney, you should provide written notice of the revocation to
your prior agent(s) and to the financial institutions where your accounts are located.

You can revoke or terminate your Power of Attorney at any time for any reason as long as you are of
sound mind. If you are no longer of sound mind, a court can remove an agent for acting improperly.

Your agent cannot make health care decisions for you. You may execute a “Health Care Proxy” to do
this.

The law governing Powers of Attorney is contained in the New York General Obligations Law, Article
5, Title 15. This law is available at a law library, or online through the New York State Senate or
Assembly websites, www.senate.state.ny.us or www.assembly.state.ny.us.

If there is anything about this document that you do not understand, you should ask a lawyer of your
own choosing to explain it to you.

Signature of Agents:
State of Pennsylvania
/s/ John S. Kreighbaum	County of Chester
John S. (Scott ) Kreighbaum
	On this, the 19th day of February, 2010, before me Michael T.
	Zelinsky, the undersigned officer, personally appeared John S.
Commonwealth of Pennsylvania	(Scott) Kreighbaum, known to me (or satisfactorily proven) to be
Notarial Seal	the person whose name is subscribed as attorney in fact for Robert
Michael T. Zelinsky, Notary Public	G. Leary, and acknowledged that he executed the same as the act of
West Whiteland Twp., Chester County	his principal for the purposes therein contained.
My Commission Expires Jan. 31, 2012
/s/ Michael T. Zelinsky
	Notary Public
State of Pennsylvania
/s/ Nicholas Morinigo	County of Chester
Nicholas Morinigo
	On this, the 19th day of February, 2010, before me Michael T.
	Zelinsky, the undersigned officer, personally appeared Nicholas
Commonwealth of Pennsylvania	Morinigo, known to me (or satisfactorily proven) to be the person
Notarial Seal	whose name is subscribed as attorney in fact for Robert G. Leary,
Michael T. Zelinsky, Notary Public	and acknowledged that he executed the same as the act of his
West Whiteland Twp., Chester County	principal for the purposes therein contained.
My Commission Expires Jan. 31, 2012
/s/ Michael T. Zelinsky
	Notary Public
	State of Connecticut
/s/ J. Neil McMurdie	County of Hartford Town of Windsor
J. Neil McMurdie
	The foregoing instrument was executed and acknowledged before
	me this 19th day of February, 2010, by J. Neil McMurdie, as
Nicole L. Molleur	attorney in fact on behalf of Robert G. Leary.
Notary Public Within and for
The State of Connecticut	/s/ Nicole L. Molleur
My commission expires: Nov. 30, 2014	Notary Public
	State of Connecticut
/s/ Michael A. Pignatella	County of Hartford Town of Windsor
Michael A. Pignatella
	The foregoing instrument was executed and acknowledged before
	me this 19th day of February, 2010, by Michael A. Pignatella, as
Nicole L. Molleur	attorney in fact on behalf of Robert G. Leary.
Notary Public Within and for
The State of Connecticut	/s/ Nicole L. Molleur
My commission expires: Nov. 30, 2014	Notary Public

IMPORTANT INFORMATION FOR THE AGENT:

When you accept the authority granted under this Power of Attorney, a special legal relationship is
created between you and the principal. This relationship imposes on you legal responsibilities that
continue until you resign or the Power of Attorney is terminated or revoked. You must:

(1) act according to any instructions from the principal, or, where there are no instructions, in the
principal’s best interest;

(2) avoid conflicts that would impair your ability to act in the principal’s best interest;

(3) keep the principal’s property separate and distinct from any assets you own or control, unless
otherwise permitted by law;

(4) keep a record of all receipts, payments, and transactions conducted for the principal; and

(5) disclose your identity as an agent whenever you act for the principal by writing or printing the
principal’s name and signing your own name as “agent” in either of the following manner: (Principal’s
Name) by (Your Signature) as Agent, or (your signature as Agent for (Principal’s Name).

You may not use the principal’s assets to benefit yourself or give major gifts to yourself or anyone else
unless the principal has specifically granted you that authority in this Power of Attorney or in a
Statutory Major Gifts Rider attached to this Power of Attorney. If you have that authority, you must act
according to any instructions of the principal or, where there are no such instructions, in the principal’s
best interest.; You may resign by giving written notice to the principal and to any co-agent, successor
agent, monitor if one has been named in this document, or the principal’s guardian if one has been
appointed. If there is anything about this document or your responsibilities that you do not understand,
you should seek legal advice.

Liability of the agent:

The meaning of the authority given to you is defined in New York’s General Obligations Law, Article
5, Title 15. If it is found that you have violated the law or acted outside the authority granted to you in
the Power of Attorney, you may be liable under the law for your violation.

POWER OF ATTORNEY

Pursuant to Item 601(b)(24) of Regulation SK and Rule 462(b) of the Securities Act of 1933
The undersigned, on behalf of the company set forth below, hereby constitutes and appoints the individuals set forth
below and each of them individually as my true and lawful attorneys with full power to them and each of them to sign
for me and in my name and in the capacity indicated below any and all amendments to the Registration Statements listed
below filed with the Securities and Exchange Commission under the Securities Act of 1933 and the Investment
Company Act of 1940 and any documentation, including Form N-8F, necessary to deregister any such registrations or to
deregister any of the entities (including any issuing separate accounts) associated with the issuance of any such
registrations.
COMPANY: ING Life Insurance and Annuity Company
INDIVIDUALS WITH POWER OF ATTORNEY:   John S. (Scott) Kreighbaum, J. Neil McMurdie, Nicholas
Morinigo and Michael A. Pignatella
REGISTRATION STATEMENTS FILED UNDER THE SECURITIES ACT OF 1933:
033-34370	033-75988	033-79122	333-105479	333-130827	333-162140
033-61897	033-75992	033-81216	333-109622	333-130833	333-162420
033-64277	033-75996	333-01107	333-109860	333-133157	333-162593
033-75248	033-75998	333-09515	333-129091	333-133158
033-75962	033-76002	333-27337	333-130822	333-134760
033-75974	033-76004	333-56297	333-130825	333-153730
033-75980	033-76018	333-72079	333-130826	333-158492
REGISTRATION STATEMENTS FILED UNDER THE INVESTMENT COMPANY ACT OF 1940:
811-02512	811-02513	811-04536	811-05906	811-08582
I hereby ratify and confirm on this 1st day of February, 2010, my signature as it may be signed by my said attorneys to
any such registration statements and any and all amendments thereto.
		Signature
		/s/ Michael S. Smith
		Michael S. Smith, Director