Exhibit 77(d)

                POLICIES WITH RESPECT TO SECURITIES INVESTMENTS

On February 26, 2002, the Board of Trustees of the Registrant adopted, on behalf
of  each of the ING  Convertible  Fund  and ING  LargeCap  Growth  Fund,  and in
accordance with the requirements of Rule 35d-1 of the Investment  Company Act of
1940, non-fundamental investment policies to (1) invest at least 80% of a Fund's
assets  in  the  type  of  investment  suggested  by  its  name,  and  (2)  give
shareholders  60 days'  prior  notice  before any  change in the 80%  investment
policy is implemented.