Exhibit 77(I)

                       TERMS OF NEW OR AMENDED SECURITIES

On  November  2, 2001,  the Board of Trustees  of the  Registrant  approved  the
issuance of a new Class of  securities  of the ING High Yield  Opportunity  Fund
designated  "Class M." Class M shares of the ING High Yield Opportunity Fund are
offered at the then-current  net asset value plus a front-end sales charge.  The
front-end  sales  charge is in such amount as is disclosed in the ING High Yield
Opportunity Fund's current prospectus or prospectus supplement and is subject to
reductions for larger purchases and such waivers or reductions as are determined
or approved by the Board of Trustees. There is no initial front-end sales charge
on purchases of an amount as disclosed in the prospectus. Class M shares are not
subject to a contingent deferred sales charge.

Class M  Shares  are  identical  to all  other  Classes  of the ING  High  Yield
Opportunity  Fund in all respects  except for Class  designation,  allocation of
certain  expenses  attributable  to Class M Shares,  and voting rights.  Class M
shareholders of the ING High Yield Opportunity Fund vote separately with respect
to issues affecting only Class M. Class M Shares represent interests in the same
investment  fund as all other  Classes and,  therefore,  are subject to the same
investment objectives,  policies and limitations as all other Classes of the ING
High Yield Opportunity Fund.

Further  description of Class M Shares appears in the  Registrant's  Amended and
Restated Rule 18f-3 Plan.