EXHIBIT 99-B.9
                         OPINION AND CONSENT OF COUNSEL






                                 Exhibit 99-B.9

[LOGO]ING


AMERICAS

US Legal Services


Julie E. Rockmore
Counsel
(860) 273-4686
Fax:  (860) 273-0385

May 21, 2002


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

RE: ING LIFE INSURANCE AND ANNUITY COMPANY (FORMERLY AETNA LIFE INSURANCE AND
    ANNUITY COMPANY) AND ITS VARIABLE ANNUITY ACCOUNT C
    POST-EFFECTIVE AMENDMENT NO. 27 TO REGISTRATION STATEMENT ON FORM N-4
    PROSPECTUS TITLE: IRA & SEP - 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

Dear Sir or Madam:

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

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

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.






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* 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:
33-75972; 33-76024; and 33-89858.




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/ Julie E. Rockmore

Julie E. Rockmore







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