Exhibit 77(c)

              SUBMISSION OF MATTERS TO A VOTE OF SECURITY HOLDERS

Special  meetings of  shareholders  of the Funds were held on February  21, 2002
(for the ING  Strategic  Income Fund and ING Money Market Fund) and on March 21,
2002 (for the High Yield Opportunity Fund) to approve the reorganization of each
Fund as a newly created  series of ING Funds Trust, a Delaware  business  trust.
The votes by shareholders of the Funds were as follows:

     (1)  ING High Yield Opportunity Fund (For: 11,739,943, Against: 359,365)
     (2)  ING Money Market Fund (For: 39,286,409, Against: 383,557)
     (3)  ING Strategic Income Fund (For: 2,751,083, Against: 9,747)