Exhibit (i)(3)

                            [DECHERT LLP LETTERHEAD]

August 28, 2003


ING Mutual Funds
7337 East Doubletree Ranch Road
Scottsdale, Arizona 85258-2034

Re.   ING Mutual Funds
      Securities Act Registration No. 33-56094
      Investment Company Act File No. 811-7428

Ladies and Gentlemen:

We have acted as counsel to the ING Mutual Funds (the "Trust"), a Delaware
statutory trust, and its series, the ING Global Equity Dividend Fund (the
"Fund"), and have a general familiarity with the Trust's business operations,
practices and procedures. In our capacity as counsel, we have examined the
Trust's Declaration of Trust, as amended to date, and are familiar with the
proceedings of the Board of Trustees authorizing the creation of the Fund and
its five classes of shares of beneficial interest denominated Class A, Class B,
Class C, Class I and Class Q (the "Shares") and the issuance of such Shares to
the public.

We have examined originals and certified copies, or copies otherwise identified
to our satisfaction as being true copies, of various corporate records of the
Trust and such other instruments, documents and records as we have deemed
necessary in order to render this opinion. We have assumed the genuineness of
all signatures, the authenticity of all documents examined by us and the
correctness of all statements of fact contained in those documents.

On the basis of the foregoing, we are of the opinion that the Shares have been
duly authorized and, when issued and sold in the manner contemplated by the
above-captioned registration statement ("Registration Statement") as filed on or
about August 29, 2003, will be legally issued, fully paid, and non-assessable by
the Trust.

We hereby consent to the inclusion of this opinion as an exhibit to the
Registration Statement and to the reference to our firm under the caption "Legal
Counsel." In giving such consent, we do not hereby admit that we are within the
category of persons whose consent is required by Section 7 of the Securities Act
of 1933, as amended, and the rules and regulations thereunder.

Sincerely,

/s/ Dechert LLP

Dechert LLP