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                                                                               .
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        CHUBB GROUP OF INSURANCE COMPANIES                   DECLARATIONS
                                                             FINANCIAL INSTITUTION INVESTMENT
        15 Mountain View Road, Warren, New Jersey 07059      COMPANY ASSET PROTECTION BOND

NAME OF ASSURED (including its SUBSIDIARIES):                Bond Number: 81905981

ING FAMILY OF FUNDS
                                                             FEDERAL INSURANCE COMPANY

7337 E. DOUBLE TREE RANCH ROAD                               Incorporated under the laws of Indiana
SCOTTSDALE, AZ 85258                                         a stock insurance company herein called the COMPANY
                                                             Capital Center, 251 North Illinois, Suite 1100
                                                             Indianapolis, IN 46204-1927


ITEM 1.     BOND PERIOD:     from       12:01 a.m. on      October 1, 2007
                                to       12:01 a.m. on      October 1, 2008

ITEM 2.     LIMITS OF LIABILITY--DEDUCTIBLE AMOUNTS:

            If "Not Covered" is inserted below opposite any specified INSURING
            CLAUSE, such INSURING CLAUSE and any other reference shall be deemed
            to be deleted. THERE SHALL BE NO DEDUCTIBLE APPLICABLE TO ANY LOSS
            under INSURING CLAUSE 1. SUSTAINED BY ANY INVESTMENT COMPANY.



                                                                      DEDUCTIBLE
INSURING CLAUSE                                  LIMIT OF LIABILITY     AMOUNT
---------------                                  ------------------   ----------
                                                                
1.  Employee                                        $ 25,000,000      $      0
2.  On Premises                                     $ 25,000,000      $ 25,000
3.  In Transit                                      $ 25,000,000      $ 25,000
4.  Forgery or Alteration                           $ 25,000,000      $ 25,000
5.  Extended Forgery                                $ 25,000,000      $ 25,000
6.  Counterfeit Money                               $ 25,000,000      $ 25,000
7.  Threats to Person                               $ 25,000,000      $ 25,000
8.  Computer System                                 $ 25,000,000      $ 25,000
9.  Voice Initiated Funds Transfer Instruction      $ 25,000,000      $ 25,000
10. Uncollectible Items of Deposit                  $    250,000      $  5,000
11. Audit Expense                                   $    250,000      $  5,000
12. Claims Expense                                  $     25,000      $      0
13. Stop Payment Order or Refusal to Pay Check      $    100,000      $      0
14. Extended Computer Systems                       $ 25,000,000      $ 25,000


ITEM 3.     THE LIABILITY OF THE COMPANY IS ALSO SUBJECT TO THE TERMS OF THE
            FOLLOWING ENDORSEMENTS EXECUTED SIMULTANEOUSLY HEREWITH:

            1 - 12

IN WITNESS WHEREOF, THE COMPANY has caused this Bond to be signed by its
authorized officers, but it shall not be valid unless also signed by an
authorized representative of the Company.

(GRAPHIC)

ICAP Bond (5-98) - Federal
Form 17-02-1421 (Ed. 5-98) Page 1 of 1



                         The COMPANY, in consideration of payment of the
                         required premium, and in reliance on the APPLICATION
                         and all other statements made and information furnished
                         to the COMPANY by the ASSURED, and subject to the
                         DECLARATIONS made a part of this Bond and to all other
                         terms and conditions of this Bond, agrees to pay the
                         ASSURED for:

INSURING CLAUSES

Employee                 1.  Loss resulting directly from LARCENY or
                             EMBEZZLEMENT committed by any EMPLOYEE, alone or in
                             collusion with others.

On Premises              2.  Loss of PROPERTY resulting directly from robbery,
                             burglary, false pretenses, common law or statutory
                             larceny, misplacement, mysterious unexplainable
                             disappearance, damage, destruction or removal, from
                             the possession, custody or control of the ASSURED,
                             while such PROPERTY is lodged or deposited at
                             premises located anywhere.

In Transit               3.  Loss of PROPERTY resulting directly from common law
                             or statutory larceny, misplacement, mysterious
                             unexplainable disappearance, damage or destruction,
                             while the PROPERTY is in transit anywhere:

                             a. in an armored motor vehicle, including loading
                                and unloading thereof,

                             b. in the custody of a natural person acting as a
                                messenger of the ASSURED, or

                             c. in the custody of a TRANSPORTATION COMPANY and
                                being transported in a conveyance other than an
                                armored motor vehicle provided, however, that
                                covered PROPERTY transported in such manner is
                                limited to the following:

                                (1)  written records,

                                (2)  securities issued in registered form, which
                                     are not endorsed or are restrictively
                                     endorsed, or

                                (3)  negotiable instruments not payable to
                                     bearer, which are not endorsed or are
                                     restrictively endorsed.

                             Coverage under this INSURING CLAUSE begins
                             immediately on the receipt of such PROPERTY by the
                             natural person or TRANSPORTATION COMPANY and ends
                             immediately on delivery to the premises of the
                             addressee or to any representative of the addressee
                             located anywhere.

ICAP Bond (5-98)
Form 17-02-1421 (Ed. 5-98) Page 1 of 19



INSURING CLAUSES
(continued)

Forgery Or Alteration    4.  Loss resulting directly from:

                             a. FORGERY on, or fraudulent material alteration
                                of, any bills of exchange, checks, drafts,
                                acceptances, certificates of deposits,
                                promissory notes, due bills, money orders,
                                orders upon public treasuries, letters of
                                credit, other written promises, orders or
                                directions to pay sums certain in money, or
                                receipts for the withdrawal of PROPERTY, or

                             b. transferring, paying or delivering any funds or
                                other PROPERTY, or establishing any credit or
                                giving any value in reliance on any written
                                instructions, advices or applications directed
                                to the ASSURED authorizing or acknowledging the
                                transfer, payment, delivery or receipt of funds
                                or other PROPERTY, which instructions, advices
                                or applications fraudulently purport to bear the
                                handwritten signature of any customer of the
                                ASSURED, or shareholder or subscriber to shares
                                of an INVESTMENT COMPANY, or of any financial
                                institution or EMPLOYEE but which instructions,
                                advices or applications either bear a FORGERY or
                                have been fraudulently materially altered
                                without the knowledge and consent of such
                                customer, shareholder, subscriber, financial
                                institution or EMPLOYEE;

                             excluding, however, under this INSURING CLAUSE any
                             loss covered under INSURING CLAUSE 5. of this Bond,
                             whether or not coverage for INSURING CLAUSE 5. is
                             provided for in the DECLARATIONS of this Bond.

                             For the purpose of this INSURING CLAUSE, a
                             mechanically reproduced facsimile signature is
                             treated the same as a handwritten signature.

Extended Forgery         5.  Loss resulting directly from the ASSURED having, in
                             good faith, and in the ordinary course of business,
                             for its own account or the account of others in any
                             capacity:

                             a. acquired, accepted or received, accepted or
                                received, sold or delivered, or given value,
                                extended credit or assumed liability, in
                                reliance on any original SECURITIES, DOCUMENTS
                                OR OTHER WRITTEN INSTRUMENTS which prove to:

                                (1)  bear a FORGERY or a fraudulently material
                                     alteration,

                                (2)  have been lost or stolen, or

                                (3)  be COUNTERFEIT, or

                             b. guaranteed in writing or witnessed any
                                signatures on any transfer, assignment, bill of
                                sale, power of attorney, guarantee, endorsement
                                or other obligation upon or in connection with
                                any SECURITIES, DOCUMENTS OR OTHER WRITTEN
                                INSTRUMENTS.

                             Actual physical possession, and continued actual
                             physical possession if taken as collateral, of
                             such SECURITIES, DOCUMENTS OR OTHER WRITTEN
                             INSTRUMENTS by an EMPLOYEE, CUSTODIAN, or a
                             Federal or State chartered deposit institution of
                             the ASSURED is a condition precedent to the ASSURED
                             having relied on such items. Release or return of
                             such collateral is an acknowledgment by the ASSURED
                             that it no longer relies on such collateral.

ICAP Bond (5-98)
Form 17-02-1421 (Ed. 5-98) Page 2 of 19



INSURING CLAUSES

Extended Forgery             For the purpose of this INSURING CLAUSE, a
(continued)                  mechanically reproduced facsimile  signature is
                             treated the same as a handwritten signature.

Counterfeit Money        6.  Loss resulting directly from the receipt by the
                             ASSURED in good faith of any COUNTERFEIT money.

Threats To Person        7.  Loss resulting directly from surrender of PROPERTY
                             away from an office of the ASSURED as a result of a
                             threat communicated to the ASSURED to do bodily
                             harm to an EMPLOYEE as defined in Section 1.e. (1),
                             EMPLOYEE, or a (2) and (5), a RELATIVE or invitee
                             of such resident of the household of such EMPLOYEE,
                             who is, or allegedly is, being held captive
                             provided, however, that prior to the surrender of
                             such PROPERTY:

                             a. the EMPLOYEE who receives the threat has made a
                                reasonable effort to notify an officer of the
                                ASSURED who is not involved in such threat, and

                             b. the ASSURED has made a reasonable effort to
                                notify the Federal Bureau of Investigation and
                                local law enforcement authorities concerning
                                such threat.

                             It is agreed that for purposes of this INSURING
                             CLAUSE, any EMPLOYEE of the ASSURED, as set forth
                             in the preceding paragraph, shall be deemed to be
                             an ASSURED hereunder, but only with respect to the
                             surrender of money, securities and other tangible
                             personal property in which such EMPLOYEE has a
                             legal or equitable interest.

Computer System          8.  Loss resulting directly from fraudulent:

                             a. entries of data into, or

                             b. changes of data elements or programs within, a
                                COMPUTER SYSTEM, provided the fraudulent entry
                                or change causes:

                                (1)  funds or other property to be transferred,
                                     paid or delivered,

                                (2)  an account of the ASSURED or of its
                                     customer to be added, deleted, debited or
                                     credited, or

                                (3)  an unauthorized account or a fictitious
                                     account to be debited or credited.

ICAP Bond (5-98)
Form 17-02-1421 (Ed. 5-98) Page 3 of 19



INSURING CLAUSES
(continued)

Voice Initiated Funds    9.  Loss resulting directly from VOICE INITIATED FUNDS
Transfer Instruction         TRANSFER INSTRUCTION directed to the ASSURED
                             authorizing the transfer of dividends or redemption
                             proceeds of INVESTMENT COMPANY shares from a
                             CUSTOMER'S account, provided such VOICE INITIATED
                             FUNDS TRANSFER INSTRUCTION was:

                             a. received at the ASSURED'S offices by those
                                EMPLOYEES of the ASSURED specifically authorized
                                to receive the VOICE INITIATED FUNDS TRANSFER
                                INSTRUCTION,

                             b. made by a person purporting to be a CUSTOMER,
                                and

                             c. made by said person for the purpose of causing
                                the ASSURED or CUSTOMER to sustain a loss or
                                making an improper personal financial gain for
                                such person or any other person.

                             In order for coverage to apply under this INSURING
                             CLAUSE, all VOICE INITIATED FUNDS TRANSFER
                             INSTRUCTIONS must be received and processed in
                             accordance with the Designated Procedures outlined
                             in the APPLICATION furnished to the COMPANY.

Uncollectible Items Of   10. Loss resulting directly from the ASSURED having
Deposit                      credited an account of a customer, shareholder or
                             subscriber on the faith of any ITEMS OF DEPOSIT
                             which prove to be uncollectible, provided that the
                             crediting of such account causes:

                             a. redemptions or withdrawals to be permitted,

                             b. shares to be issued, or

                             c. dividends to be paid,

                             from an account of an INVESTMENT COMPANY.

                             In order for coverage to apply under this INSURING
                             CLAUSE, the ASSURED must hold ITEMS OF DEPOSIT for
                             the minimum number of days stated in the
                             APPLICATION before permitting any redemptions or
                             withdrawals, issuing any shares or paying any
                             dividends with respect to such ITEMS OF DEPOSIT.

                             ITEMS OF DEPOSIT shall not be deemed uncollectible
                             until the ASSURED'S standard collection procedures
                             have failed.

Audit Expense            11. Expense incurred by the ASSURED for that part of
                             the cost of audits or examinations required by any
                             governmental regulatory authority or
                             self-regulatory organization to be conducted by
                             such authority, organization or their appointee by
                             reason of the discovery of loss sustained by the
                             ASSURED and covered by this Bond.

ICAP Bond (5-98)
Form 17-02-1421 (Ed. 5-98) Page 4 of 19



GENERAL AGREEMENTS

Additional Companies         A. If more than one corporation, or INVESTMENT
Included As Assured             COMPANY, or any combination of them is included
                                as the ASSURED herein:

                                (1)  The total liability of the COMPANY under
                                     this Bond for loss or losses sustained by
                                     any one or more or all of them shall not
                                     exceed the limit for which the COMPANY
                                     would be liable under this Bond if all such
                                     loss were sustained by any one of them.

                                (2)  Only the first named ASSURED shall be
                                     deemed to be the sole agent of the others
                                     for all purposes under this Bond, including
                                     but not limited to the giving or receiving
                                     of any notice or proof required to be given
                                     and for the purpose of effecting or
                                     accepting any amendments to or termination
                                     of this Bond. The COMPANY shall furnish
                                     each INVESTMENT COMPANY with a copy of the
                                     Bond and with any amendment thereto,
                                     together with a copy of each formal filing
                                     of claim by any other named ASSURED and
                                     notification of the terms of the settlement
                                     of each such claim prior to the execution
                                     of such settlement.

                                (3)  The COMPANY shall not be responsible for
                                     the proper application of any payment made
                                     hereunder to the first named ASSURED.

                                (4)  Knowledge possessed or discovery made by
                                     any partner, director, trustee, officer or
                                     supervisory employee of any ASSURED shall
                                     constitute knowledge or discovery by all
                                     the ASSUREDS for the purposes of this Bond.

                                (5)  If the first named ASSURED ceases for any
                                     reason to be covered under this Bond, then
                                     the ASSURED next named on the APPLICATION
                                     shall thereafter be considered as the first
                                     named ASSURED for the purposes of this
                                     Bond.

Representation Made By       B. The ASSURED represents that all information it
Assured                         has furnished in the APPLICATION for this Bond
                                or otherwise is complete, true and correct. Such
                                APPLICATION and other information constitute
                                part of this Bond.

                                The ASSURED must promptly notify the COMPANY of
                                any change in any fact or circumstance which
                                materially affects the risk assumed by the
                                COMPANY under this Bond.

                                Any intentional misrepresentation, omission,
                                concealment or incorrect statement of a material
                                fact, in the APPLICATION or otherwise, shall be
                                grounds for recision of this Bond.

ICAP Bond (5-98)
Form 17-02-1421 (Ed. 5-98) Page 5 of 19



GENERAL AGREEMENTS
(continued)

Additional Offices Or        C. If the ASSURED, other than an INVESTMENT
Employees - Consolidation,      COMPANY, while this Bond is in force, merges or
Merger Or Purchase Or           consolidates with, or purchases or acquires
Acquisition Of                  assets or liabilities of another institution,
Or Liabilities - Notice To      the ASSURED shall not have the coverage afforded
Company                         under this ASSETS Bond for loss which has:

                                (1)  occurred or will occur on premises, or

                                (2)  been caused or will be caused by an
                                     employee, or

                                (3)  arisen or will arise out of the assets or
                                     liabilities,

                                of such institution, unless the ASSURED:

                                a.   gives the COMPANY written notice of the
                                     proposed consolidation, merger

                                     or

                                     purchase or acquisition of assets or
                                     liabilities prior to the proposed effective
                                     date of such action, and

                                b.   obtains the written consent of the COMPANY
                                     to extend some or all of the coverage
                                     provided by this Bond to such additional
                                     exposure, and

                                c.   on obtaining such consent, pays to the
                                     COMPANY an additional premium.

Change Of Control -          D. When the ASSURED learns of a change in control
Notice To Company               (other than in an INVESTMENT COMPANY), as set
                                forth in Section 2(a) (9) of the Investment
                                Company Act of 1940, the ASSURED shall within
                                sixty (60) days give written notice to the
                                COMPANY setting forth:

                                (1)  the names of the transferors and
                                     transferees (or the names of the beneficial
                                     owners if the voting securities are
                                     registered in another name),

                                (2)  the total number of voting securities owned
                                     by the transferors and the transferees (or
                                     the beneficial owners), both immediately
                                     before and after the transfer, and

                                (3)  the total number of outstanding voting
                                     securities.

                                Failure to give the required notice shall result
                                in termination of coverage for any loss
                                involving a transferee, to be effective on the
                                date of such change in control.

Court Costs And              E. The COMPANY will indemnify the ASSURED for court
Attorneys' Fees                 costs and reasonable attorneys' fees incurred
                                and paid by the ASSURED in defense, whether or
                                not successful, whether or not fully litigated
                                on the merits and whether or not settled, of any
                                claim, suit or legal proceeding with respect to
                                which the ASSURED would be entitled to recovery
                                under this Bond. However, with respect to
                                INSURING CLAUSE 1., this Section shall only
                                apply in the event that:

                                (1)  an EMPLOYEE admits to being guilty of
                                     LARCENY OR EMBEZZLEMENT,

                                (2)  an EMPLOYEE is adjudicated to be guilty of
                                     LARCENY OR EMBEZZLEMENT, or

ICAP Bond (5-98)
Form 17-02-1421 (Ed. 5-98) Page 6 of 19



GENERAL AGREEMENTS

Court Costs And          (3)    in the absence of 1 or 2 above, an arbitration
Attorneys' Fees                 panel agrees, after a review of an agreed
(continued)                     statement of facts between the COMPANY and the
                                ASSURED, that an EMPLOYEE would be found guilty
                                of LARCENY OR EMBEZZLEMENT if such EMPLOYEE were
                                prosecuted.

                         The ASSURED shall promptly give notice to the COMPANY
                         of any such suit or legal proceeding and at the request
                         of the COMPANY shall furnish copies of all pleadings
                         and pertinent papers to the COMPANY. The COMPANY may,
                         at its sole option, elect to conduct the defense of all
                         or part of such legal proceeding. The defense by the
                         COMPANY shall be in the name of the ASSURED through
                         attorneys selected by the COMPANY. The ASSURED shall
                         provide all reasonable information and assistance as
                         required by the COMPANY for such defense.

                         If the COMPANY declines to defend the ASSURED, no
                         settlement without the prior written consent of the
                         COMPANY nor judgment against the ASSURED shall
                         determine the existence, extent or amount of coverage
                         under this Bond.

                         If the amount demanded in any such suit or legal
                         proceeding is within the DEDUCTIBLE AMOUNT, if any, the
                         COMPANY shall have no liability for court costs and
                         attorney's fees incurred in defending all or part of
                         such suit or legal proceeding.

                         If the amount demanded in any such suit or legal
                         proceeding is in excess of the LIMIT OF LIABILITY
                         stated in ITEM 2. of the DECLARATIONS for the
                         applicable INSURING CLAUSE, the COMPANY'S liability for
                         court costs and attorney's fees incurred in defending
                         all or part of such suit or legal proceedings is
                         limited to the proportion of such court costs and
                         attorney's fees incurred that the LIMIT OF LIABILITY
                         stated in ITEM 2. of the DECLARATIONS for the
                         applicable INSURING CLAUSE bears to the total of the
                         amount demanded in such suit or legal proceeding.

                         If the amount demanded is any such suit or legal
                         proceeding is in excess of the DEDUCTIBLE AMOUNT, if
                         any, but within the LIMIT OF LIABILITY stated in ITEM
                         2. of the DECLARATIONS for the applicable INSURING
                         CLAUSE, the COMPANY'S liability for court costs and
                         attorney's fees incurred in defending all or part of
                         such suit or legal proceedings shall be limited to the
                         proportion of such court costs or attorney's fees that
                         the amount demanded that would be payable under this
                         Bond after application of the DEDUCTIBLE AMOUNT, bears
                         to the total amount demanded.

                         Amounts paid by the COMPANY for court costs and
                         attorneys' fees shall be in addition to the LIMIT OF
                         LIABILITY stated in ITEM 2. of the DECLARATIONS.

ICAP Bond (5-98)
Form 17-02-1421 (Ed. 5-98) Page 7 of 19



CONDITIONS AND
LIMITATIONS

Definitions              1.  As used in this Bond:

                             a. COMPUTER SYSTEM means a computer and all input,
                                output, processing, storage, off-line media
                                libraries, and communication facilities which
                                are connected to the computer and which are
                                under the control and supervision of the
                                operating system(s) or application(s) software
                                used by the ASSURED.

                             b. COUNTERFEIT means an imitation of an actual
                                valid original which is intended to deceive and
                                be taken as the original.

                             c. CUSTODIAN means the institution designated by an
                                INVESTMENT COMPANY to maintain possession and
                                control of its assets.

                             d. CUSTOMER means an individual, corporate,
                                partnership, trust customer, shareholder or
                                subscriber of an INVESTMENT COMPANY which has a
                                written agreement with the ASSURED for VOICE
                                INITIATED FUNDS TRANSFER INSTRUCTION.

                             e. EMPLOYEE means:

                                (1) an officer of the ASSURED,

                                (2)  a natural person while in the regular
                                     service of the ASSURED at any of the
                                     ASSURED'S premises and compensated
                                     directly by the ASSURED through its
                                     payroll system and subject to the United
                                     States Internal Revenue Service Form W-2
                                     or equivalent income reporting plans of
                                     other countries, and whom the ASSURED
                                     has the right to control and direct both
                                     as to the result to be accomplished and
                                     details and means by which such result
                                     is accomplished in the performance of
                                     such service,

                                (3)  a guest student pursuing studies or
                                     performing duties in any of the ASSURED'S
                                     premises,

                                (4)  an attorney retained by the ASSURED and an
                                     employee of such attorney while either is
                                     performing legal services for the ASSURED,

                                (5)  a natural person provided by an employment
                                     contractor to perform employee duties for
                                     the ASSURED under the ASSURED'S supervision
                                     at any of the ASSURED'S premises,

                                (6)  an employee of an institution merged or
                                     consolidated with the ASSURED prior to
                                     the effective date of this Bond,

                                (7)  a director or trustee of the ASSURED, but
                                     only while performing acts within the scope
                                     of the customary and usual duties of any
                                     officer or other employee of the ASSURED or
                                     while acting as a member of any committee
                                     duly elected or appointed to examine or
                                     audit or have custody of or access to
                                     PROPERTY of the ASSURED, or

ICAP Bond (5-98)
Form 17-02-1421 (Ed. 5-98) Page 8 of 19



CONDITIONS AND
LIMITATIONS

Definitions             (8)  each natural person, partnership or corporation
(continued)                  authorized by written agreement with the ASSURED to
                             perform services as electronic data processor of
                             checks or other accounting records related to such
                             checks but only while such person, partnership or
                             corporation is actually performing such services
                             and not:

                             a. creating, preparing, modifying or maintaining
                                the ASSURED'S computer software or programs, or

                             b. acting as transfer agent or in any other agency
                                capacity in issuing checks, drafts or securities
                                for the ASSURED,

                        (9)  any partner, officer or employee of an investment
                             advisor, an underwriter (distributor), a transfer
                             agent or shareholder accounting recordkeeper, or an
                             administrator, for an INVESTMENT COMPANY while
                             performing acts coming within the scope of the
                             customary and usual duties of an officer or
                             employee of an INVESTMENT COMPANY or acting as a
                             member of any committee duly elected or appointed
                             to examine, audit or have custody of or access to
                             PROPERTY of AN INVESTMENT COMPANY.

                             The term EMPLOYEE shall not include any partner,
                             officer or employee of a transfer agent,
                             shareholder accounting recordkeeper or
                             administrator:

                             a. which is not an "affiliated person" (as defined
                                in Section 2(a) of the Investment Company Act of
                                1940) of an INVESTMENT COMPANY or of the
                                investment advisor or underwriter (distributor)
                                of such INVESTMENT COMPANY, or

                             b. which is a "bank" (as defined in Section 2(a) of
                                the Investment Company Act of 1940).

                                This Bond does not afford coverage in favor of
                                the employers of persons as set forth in e. (4),
                                (5) and (8) above, and upon payment to the
                                ASSURED by the COMPANY resulting directly from
                                LARCENY OR EMBEZZLEMENT committed by any of the
                                partners, officers or employees of such
                                employers, whether acting alone or in collusion
                                with others, an assignment of such of the
                                ASSURED'S rights and causes of action as it may
                                have against such employers by reason of such
                                acts so committed shall, to the extent of such
                                payment, be given by the ASSURED to the COMPANY,
                                and the ASSURED shall execute all papers
                                necessary to secure to the COMPANY the rights
                                provided for herein.

                             Each employer of persons as set forth in e.(4), (5)
                             and (8) above and the partners, officers and other
                             employees of such employers shall collectively be
                             deemed to be one person for all the purposes of
                             this Bond; excepting, however, the fifth paragraph
                             of Section 13.

                             Independent contractors not specified in e.(4), (5)
                             or (8) above, intermediaries, agents, brokers or
                             other representatives of the same general character
                             shall not be considered EMPLOYEES.

ICAP Bond (5-98)
Form 17-02-1421 (Ed. 5-98) Page 9 of 19



CONDITIONS AND
LIMITATIONS

Definitions             f.  FORGERY means the signing of the name of another
(continued)                 natural person with the intent to deceive but does
                            not mean a signature which consists in whole or in
                            part of one's own name, with or without authority,
                            in any capacity for any purpose.

                        g.  INVESTMENT COMPANY means any investment company
                            registered under the Investment Company Act of 1940
                            and listed under the NAME OF ASSURED on the
                            DECLARATIONS.

                        h.  ITEMS OF DEPOSIT means one or more checks or drafts
                            drawn upon a financial institution in the United
                            States of America.

                        i.  LARCENY OR EMBEZZLEMENT means larceny or
                            embezzlement as defined in Section 37 of the
                            Investment Company Act of 1940.

                        j.  PROPERTY means money, revenue and other stamps;
                            securities; including any note, stock, treasury
                            stock, bond, debenture, evidence of indebtedness,
                            certificate of deposit, certificate of interest or
                            participation in any profit- sharing agreement,
                            collateral trust certificate, preorganization
                            certificate or subscription, transferable share,
                            investment contract, voting trust certificate,
                            certificate of deposit for a security, fractional
                            undivided interest in oil, gas, or other mineral
                            rights, any interest or instruments commonly known
                            as a security under the Investment Company Act of
                            1940, any other certificate of interest or
                            participation in, temporary or interim certificate
                            for, receipt for, guarantee of, or warrant or right
                            to subscribe to or purchase any of the foregoing;
                            bills of exchange; acceptances; checks; withdrawal
                            orders; money orders; travelers' letters of credit;
                            bills of lading; abstracts of title; insurance
                            policies, deeds, mortgages on real estate and/or
                            upon chattels and interests therein; assignments of
                            such policies, deeds or mortgages; other valuable
                            papers, including books of accounts and other
                            records used by the ASSURED in the conduct of its
                            business (but excluding all electronic data
                            processing records); and, all other instruments
                            similar to or in the nature of the foregoing in
                            which the ASSURED acquired an interest at the time
                            of the ASSURED'S consolidation or merger with, or
                            purchase of the principal assets of, a predecessor
                            or which are held by the ASSURED for any purpose or
                            in any capacity and whether so held gratuitously or
                            not and whether or not the ASSURED is liable
                            therefor.

                        k.  RELATIVE means the spouse of an EMPLOYEE or partner
                            of the ASSURED and any unmarried child supported
                            wholly by, or living in the home of, such EMPLOYEE
                            or partner and being related to them by blood,
                            marriage or legal guardianship.

                        l.  SECURITIES, DOCUMENTS OR OTHER WRITTEN INSTRUMENTS
                            means original (including original counterparts)
                            negotiable or non-negotiable instruments, or
                            assignments thereof, which in and of themselves
                            represent an equitable interest, ownership, or debt
                            and which are in the ordinary course of business
                            transferable by delivery of such instruments with
                            any necessary endorsements or assignments.

ICAP Bond (5-98)
Form 17-02-1421 (Ed. 5-98) Page 10 of 19




CONDITIONS AND
LIMITATIONS

Definitions                   m.   SUBSIDIARY means any organization that, at
(continued)                        the inception date of this Bond, (continued)
                                   is named in the APPLICATION or is created
                                   during the BOND PERIOD and of which more than
                                   fifty percent (50%) of the outstanding
                                   securities or voting rights representing the
                                   present right to vote for election of
                                   directors is owned or controlled by the
                                   ASSURED either directly or through one or
                                   more of its subsidiaries.

                              n.   TRANSPORTATION COMPANY means any organization
                                   which provides its own or its leased vehicles
                                   for transportation or which provides freight
                                   forwarding or air express services.

                              o.   VOICE INITIATED ELECTION means any election
                                   concerning dividend options available to
                                   INVESTMENT COMPANY shareholders or
                                   subscribers which is requested by voice over
                                   the telephone.

                              p.   VOICE INITIATED REDEMPTION means any
                                   redemption of shares issued by an INVESTMENT
                                   COMPANY which is requested by voice over the
                                   telephone.

                              q.   VOICE INITIATED FUNDS TRANSFER INSTRUCTION
                                   means any VOICE INITIATED REDEMPTION or VOICE
                                   INITIATED ELECTION.

                              For the purposes of these definitions, the
                              singular includes the plural and the plural
                              includes the singular, unless otherwise indicated.

General Exclusions -      2.  THIS BOND DOES NOT DIRECTLY OR INDIRECTLY COVER:
Applicable to All
Insuring Clauses              a.   loss not reported to the COMPANY in writing
                                   within sixty (60) days after termination of
                                   this Bond as an entirety;

                              b.   loss due to riot or civil commotion outside
                                   the United States of America and Canada, or
                                   any loss due to military, naval or usurped
                                   power, war or insurrection. This Section
                                   2.b., however, shall not apply to loss which
                                   occurs in transit in the circumstances
                                   recited in INSURING CLAUSE 3., provided that
                                   when such transit was initiated there was no
                                   knowledge on the part of any person acting
                                   for the ASSURED of such riot, civil
                                   commotion, military, naval or usurped power,
                                   war or insurrection;

                              c.   loss resulting from the effects of nuclear
                                   fission or fusion or radioactivity;

                              d.   loss of potential income including, but not
                                   limited to, interest and dividends not
                                   realized by the ASSURED or by any customer
                                   of the ASSURED;

                              e.   damages of any type for which the ASSURED is
                                   legally liable, except compensatory damages,
                                   but not multiples thereof, arising from a
                                   loss covered under this Bond;

                              f.   costs, fees and expenses incurred by the
                                   ASSURED in establishing the existence of or
                                   amount of loss under this Bond, except to the
                                   extent covered under INSURING CLAUSE 11.;

                              g.   loss resulting from indirect or consequential
                                   loss of any nature;

ICAP Bond (5-98)
Form 17-02-1421 (Ed. 5-98) Page 11 of 19





CONDITIONS AND
LIMITATIONS

General Exclusions -          h.   loss resulting from dishonest acts by any
Applicable to All                  member of the Board of Directors or Board of
Insuring Clauses                   Trustees of the ASSURED who is not an
(continued)                        EMPLOYEE, acting alone or in collusion with
                                   others;

                              i.   loss, or that part of any loss, resulting
                                   solely from any violation by the ASSURED or
                                   by any EMPLOYEE:

                                   (1)  of any law regulating:

                                        a. the issuance, purchase or sale of
                                           securities,

                                        b. securities transactions on security
                                           or commodity exchanges or the over
                                           the counter market,

                                        c. investment companies,

                                        d. investment advisors, or

                                   (2)  of any rule or regulation made pursuant
                                        to any such law; or

                              j.   loss of confidential information,
                                   material or data;

                              k.   loss resulting from voice requests
                                   or instructions received over the
                                   telephone, provided however, this
                                   Section 2.k. shall not apply to
                                   INSURING CLAUSE 7. or 9.

Specific Exclusions -  3. THIS BOND DOES NOT DIRECTLY OR INDIRECTLY COVER:
Applicable To All
Insuring Clauses          a.  loss caused by an EMPLOYEE, provided, however,
Except Insuring               this Section 3.a. shall not apply to loss covered
Clause 1.                     under INSURING CLAUSE 2. or 3. which results
                              directly from misplacement, mysterious
                              unexplainable disappearance, or damage or
                              destruction of PROPERTY;

                          b.  loss through the surrender of property away from
                              premises of the ASSURED as a result of a threat:

                              (1)  to do bodily harm to any natural person,
                                   except loss of PROPERTY in transit in the
                                   custody of any person acting as messenger of
                                   the ASSURED, provided that when such transit
                                   was initiated there was no knowledge by the
                                   ASSURED of any such threat, and provided
                                   further that this Section 3.b. shall not
                                   apply to INSURING CLAUSE 7., or

                              (2)  to do damage to the premises or PROPERTY of
                                   the ASSURED;

                          c.  loss resulting from payments made or withdrawals
                              from any account involving erroneous credits to
                              such account;

                          d.  loss involving ITEMS OF DEPOSIT which are not
                              finally paid for any reason provided however,
                              that this Section 3.d. shall not apply to
                              INSURING CLAUSE 10.;

                          e.  loss of property while in the mail;

ICAP Bond (5-98)
Form 17-02-1421 (Ed. 5-98) Page 12 of 19





CONDITIONS AND
LIMITATIONS

Specific Exclusions -     f.  loss resulting from the failure for any reason of
Applicable To All             a financial or depository institution, its
Insuring Clauses              receiver or other liquidator to pay or deliver
Except Insuring               funds or other PROPERTY to the ASSURED provided
Clause 1. (continued)         further that this Section 3.f. shall not apply to
                              loss of PROPERTY resulting directly from robbery,
                              burglary, misplacement, mysterious unexplainable
                              disappearance, damage, destruction or removal
                              from the possession, custody or control of the
                              ASSURED.

                          g.  loss of PROPERTY while in the custody of a
                              TRANSPORTATION COMPANY, provided however, that
                              this Section 3.g. shall not apply to INSURING
                              CLAUSE 3.;

                          h.  loss resulting from entries or changes made by a
                              natural person with authorized access to a
                              COMPUTER SYSTEM who acts in good faith on
                              instructions, unless such instructions are given
                              to that person by a software contractor or its
                              partner, officer, or employee authorized by the
                              ASSURED to design, develop, prepare, supply,
                              service, write or implement programs for the
                              ASSURED's COMPUTER SYSTEM; or

                          i.  loss resulting directly or indirectly from the
                              input of data into a COMPUTER SYSTEM terminal,
                              either on the premises of the customer of the
                              ASSURED or under the control of such a customer,
                              by a customer or other person who had authorized
                              access to the customer's authentication mechanism.

Specific Exclusions -  4. THIS BOND DOES NOT DIRECTLY OR INDIRECTLY COVER:
Applicable To All
Insuring Clauses          a.  loss resulting from the complete or partial
Except Insuring               non-payment of or default on any loan whether
Clauses 1., 4., And 5.        such loan was procured in good faith or through
                              trick, artifice, fraud or false pretenses;
                              provided, however, this Section 4.a. shall not
                              apply to INSURING CLAUSE 8.;

                          b.  loss resulting from forgery or any alteration;

                          c.  loss involving a counterfeit provided, however,
                              this Section 4.c. shall not apply to INSURING
                              CLAUSE 5. or 6.

Limit Of Liability/    5. At all times prior to termination of this Bond, this
Non-Reduction And Non-    Bond shall continue in force for the limit stated in
Accumulation Of           the applicable sections of ITEM 2. of the
Liability                 DECLARATIONS, notwithstanding any previous loss for
                          which the COMPANY may have paid or be liable to pay
                          under this Bond provided, however, that the liability
                          of the COMPANY under this Bond with respect to all
                          loss resulting from:

                          a.  any one act of burglary, robbery or hold-up, or
                              attempt thereat, in which no EMPLOYEE is concerned
                              or implicated, or

                          b.  any one unintentional or negligent act on the
                              part of any one person resulting in damage to
                              or destruction or misplacement of PROPERTY, or

                          c.  all acts, other than those specified in a. above,
                              of any one person, or

ICAP Bond (5-98)
Form 17-02-1421 (Ed. 5-98) Page 13 of 19



CONDITIONS AND
LIMITATIONS

Limit Of Liability/Non-   d.  any one casualty or event other than those
Reduction And Non-            specified in a., b., or c. above, shall be deemed
Accumulation Of               to be one loss and shall be limited to the
Liability (continued)         applicable LIMIT OF LIABILITY stated in ITEM 2. of
                              the DECLARATIONS of this Bond irrespective of the
                              total amount of such loss or losses and shall not
                              be cumulative in amounts from year to year or from
                              period to period.

                          All acts, as specified in c. above, of any one person
                          which

                          i.  directly or indirectly aid in any way wrongful
                              acts of any other person or persons, or

                          ii. permit the continuation of wrongful acts of any
                              other person or persons

                          whether such acts are committed with or without the
                          knowledge of the wrongful acts of the person so
                          aided, and whether such acts are committed with or
                          without the intent to aid such other person, shall be
                          deemed to be one loss with the wrongful acts of all
                          persons so aided.

Discovery              6. This Bond applies only to loss first discovered by an
                          officer of the ASSURED during the BOND PERIOD.
                          Discovery occurs at the earlier of an officer of the
                          ASSURED being aware of:

                          a.  facts which may subsequently result in a loss of
                              a type covered by this Bond, or

                          b.  an actual or potential claim in which it is
                              alleged that the ASSURED is liable to a third
                              party,

                          regardless of when the act or acts causing or
                          contributing to such loss occurred, even though the
                          amount of loss does not exceed the applicable
                          DEDUCTIBLE AMOUNT, or the exact amount or details of
                          loss may not then be known.

Notice To Company -    7. a.  The ASSURED shall give the COMPANY notice thereof
Proof - Legal                 at the earliest practicable moment, not to exceed
Proceedings Against           sixty (60) days after discovery of loss, in an
Company                       amount that is in excess of 50% of the applicable
                              DEDUCTIBLE AMOUNT, as stated in ITEM 2. of the
                              DECLARATIONS.

                          b.  The ASSURED shall furnish to the COMPANY proof of
                              loss, duly sworn to, with full particulars within
                              six (6) months after such discovery.

                          c.  Securities listed in a proof of loss shall be
                              identified by certificate or bond numbers, if
                              issued with them.

                          d.  Legal proceedings for the recovery of any loss
                              under this Bond shall not be brought prior to the
                              expiration of sixty (60) days after the proof of
                              loss is filed with the COMPANY or after the
                              expiration of twenty-four (24) months from the
                              discovery of such loss.

                          e.  This Bond affords coverage only in favor of the
                              ASSURED. No claim, suit, action or legal
                              proceedings shall be brought under this Bond by
                              anyone other than the ASSURED.

ICAP Bond (5-98)
Form 17-02-1421 (Ed. 5-98) Page 14 of 19



CONDITIONS AND
LIMITATIONS

Notice To Company -       f.  Proof of loss involving VOICE INITIATED FUNDS
Proof - Legal                 TRANSFER INSTRUCTION shall include electronic
Proceedings Against           recordings of such instructions.
Company (continued)

Deductible Amount      8. The COMPANY shall not be liable under any INSURING
                          CLAUSES of this Bond on account of loss unless the
                          amount of such loss, after deducting the net amount
                          of all reimbursement and/or recovery obtained or made
                          by the ASSURED, other than from any Bond or policy of
                          insurance issued by an insurance company and covering
                          such loss, or by the COMPANY on account thereof prior
                          to payment by the COMPANY of such loss, shall exceed
                          the DEDUCTIBLE AMOUNT set forth in ITEM 3. of the
                          DECLARATIONS, and then for such excess only, but in
                          no event for more than the applicable LIMITS OF
                          LIABILITY stated in ITEM 2. of the DECLARATIONS.

                          There shall be no deductible applicable to any loss
                          under INSURING CLAUSE 1. sustained by any INVESTMENT
                          COMPANY.

Valuation              9. BOOKS OF ACCOUNT OR OTHER RECORDS

                          The value of any loss of PROPERTY consisting of books
                          of account or other records used by the ASSURED in the
                          conduct of its business shall be the amount paid by
                          the ASSURED for blank books, blank pages, or other
                          materials which replace the lost books of account
                          or other records, plus the cost of labor paid by the
                          ASSURED for the actual transcription or copying of
                          data to reproduce such books of account or other
                          records.

                          The value of any loss of PROPERTY other than books of
                          account or other records used by the ASSURED in the
                          conduct of its business, for which a claim is made
                          shall be determined by the average market value of
                          such PROPERTY on the business day immediately
                          preceding discovery of such loss provided, however,
                          that the value of any PROPERTY replaced by the
                          ASSURED with the consent of the COMPANY and prior to
                          the settlement of any claim for such PROPERTY shall
                          be the actual market value at the time of replacement.

                          In the case of a loss of interim certificates,
                          warrants, rights or other securities, the production
                          of which is necessary to the exercise of subscription,
                          conversion, redemption or deposit privileges, the
                          value of them shall be the market value of such
                          privileges immediately preceding their expiration if
                          said loss is not discovered until after their
                          expiration. If no market price is quoted for such
                          PROPERTY or for such privileges, the value shall be
                          fixed by agreement between the parties.

                          OTHER PROPERTY

                          The value of any loss of PROPERTY, other than as
                          stated above, shall be the actual cash value or the
                          cost of repairing or replacing such PROPERTY with
                          PROPERTY of like quality and value, whichever is less.

ICAP Bond (5-98)
Form 17-02-1421 (Ed. 5-98) Page 15 of 19



CONDITIONS AND
LIMITATIONS
(continued)

Securities Settlement 10. In the event of a loss of securities covered under
                          this Bond, the COMPANY may, at its sole discretion,
                          purchase replacement securities, tender the value
                          of the securities in money, or issue its indemnity to
                          effect replacement securities.

                          The indemnity required from the ASSURED under the
                          terms of this Section against all loss, cost or
                          expense arising from the replacement of securities
                          by the COMPANY'S indemnity shall be:

                          a.  for securities having a value less than or
                              equal to the applicable DEDUCTIBLE AMOUNT - one
                              hundred (100%) percent;

                          b.  for securities having a value in excess of the
                              DEDUCTIBLE AMOUNT but within the applicable LIMIT
                              OF LIABILITY - the percentage that the DEDUCTIBLE
                              AMOUNT bears to the value of the securities;

                          c.  for securities having a value greater than the
                              applicable LIMIT OF LIABILITY - the percentage
                              that the DEDUCTIBLE AMOUNT and portion in excess
                              of the applicable LIMIT OF LIABILITY bears to the
                              value of the securities.

                          The value referred to in Section 10.a., b., and c. is
                          the value in accordance with Section 9, VALUATION,
                          regardless of the value of such securities at the time
                          the loss under the COMPANY'S indemnity is sustained.

                          The COMPANY is not required to issue its indemnity for
                          any portion of a loss of securities which is not
                          covered by this Bond; however, the COMPANY may do so
                          as a courtesy to the ASSURED and at its sole
                          discretion.

                          The ASSURED shall pay the proportion of the Company's
                          premium charge for the Company's indemnity as set
                          forth in Section 10.a., b., and c. No portion of the
                          LIMIT OF LIABILITY shall be used as payment of premium
                          for any indemnity purchased by the ASSURED to obtain
                          replacement securities.

Subrogation           11. In the event of a payment under this Bond, the COMPANY
Assignment -              shall be subrogated to all of the ASSURED'S rights of
Recovery                  recovery against any person or entity to the extent of
                          such payment. On request, the ASSURED shall deliver to
                          the COMPANY an assignment of the ASSURED'S rights,
                          title and interest and causes of action against any
                          person or entity to the extent of such payment.

                          Recoveries, whether effected by the COMPANY or by the
                          ASSURED, shall be applied net of the expense of such
                          recovery in the following order:

                          a.  first, to the satisfaction of the ASSURED'S loss
                              which would otherwise have been paid but for the
                              fact that it is in excess of the applicable LIMIT
                              OF LIABILITY,

                          b.  second, to the COMPANY in satisfaction of amounts
                              paid in settlement of the ASSURED'S claim,

                          c.  third, to the ASSURED in satisfaction of the
                              applicable DEDUCTIBLE AMOUNT, and

ICAP Bond (5-98)
Form 17-02-1421 (Ed. 5-98) Page 16 of 19



CONDITIONS AND
LIMITATIONS

Subrogation -             d.  fourth, to the ASSURED in satisfaction of any loss
Assignment - Recovery         suffered by the ASSURED which was not covered
(continued)                   under this Bond.

                              Recovery from reinsurance or indemnity of the
                              COMPANY shall not be deemed a recovery under this
                              section.

Cooperation Of        12. At the COMPANY'S request and at reasonable times and
Assured                   places designated by the COMPANY, the ASSURED shall:

                          a.  submit to examination by the COMPANY and subscribe
                              to the same under oath,

                          b.  produce for the COMPANY'S examination all
                              pertinent records, and

                          c.  cooperate with the COMPANY in all matters
                              pertaining to the loss.

                          The ASSURED shall execute all papers and render
                          assistance to secure to the COMPANY the rights and
                          causes of action provided for under this Bond. The
                          ASSURED shall do nothing after loss to prejudice such
                          rights or causes of action.

Termination           13. If the Bond is for a sole ASSURED, it shall not be
                          terminated unless written notice shall have been given
                          by the acting party to the affected party and to the
                          Securities and Exchange Commission, Washington, D.C.,
                          not less than sixty (60) days prior to the effective
                          date of such termination.

                          If the Bond is for a joint ASSURED, it shall not be
                          terminated unless written notice shall have been given
                          by the acting party to the affected party, and by the
                          COMPANY to all ASSURED INVESTMENT COMPANIES and to the
                          Securities and Exchange Commission, Washington, D.C.,
                          not less than sixty (60) days prior to the effective
                          date of such termination.

                          This Bond will terminate as to any one ASSURED, other
                          than an INVESTMENT COMPANY:

                          a.  immediately on the taking over of such ASSURED by
                              a receiver or other liquidator or by State or
                              Federal officials, or

                          b.  immediately on the filing of a petition under any
                              State or Federal statute relative to bankruptcy or
                              reorganization of the ASSURED, or assignment for
                              the benefit of creditors of the ASSURED, or

                          c.  immediately upon such ASSURED ceasing to exist,
                              whether through merger into another entity,
                              disposition of all of its assets or otherwise.

                          The COMPANY shall refund the unearned premium computed
                          at short rates in accordance with the standard short
                          rate cancellation tables if terminated by the ASSURED
                          or pro rata if terminated for any other reason.

ICAP Bond (5-98)
Form 17-02-1421 (Ed. 5-98) Page 17 of 19



CONDITIONS AND
LIMITATIONS

Termination               If any partner, director, trustee, or officer or
(continued)               supervisory employee of an ASSURED not acting in
                          collusion with an EMPLOYEE learns of any dishonest act
                          committed by such EMPLOYEE at any time, whether in the
                          employment of the ASSURED or otherwise, whether or
                          not such act is of the type covered under this Bond,
                          and whether against the ASSURED or any other person or
                          entity, the ASSURED:

                          a.  shall immediately remove such EMPLOYEE from a
                              position that would enable such EMPLOYEE to cause
                              the ASSURED to suffer a loss covered by this Bond;
                              and

                          b.  within forty-eight (48) hours of learning that an
                              EMPLOYEE has committed any dishonest act, shall
                              notify the COMPANY, of such action and provide
                              full particulars of such dishonest act.

                          The COMPANY may terminate coverage as respects any
                          EMPLOYEE sixty (60) days after written notice is
                          received by each ASSURED INVESTMENT COMPANY and the
                          Securities and Exchange Commission, Washington,
                          D.C. of its desire to terminate this Bond as to such
                          EMPLOYEE.

Other Insurance       14. Coverage under this Bond shall apply only as excess
                          over any valid and collectible insurance, indemnity or
                          suretyship obtained by or on behalf of:

                          a.  the ASSURED,

                          b.  a TRANSPORTATION COMPANY, or

                          c.  another entity on whose premises the loss occurred
                              or which employed the person causing the loss or
                              engaged the messenger conveying the PROPERTY
                              involved.

Conformity            15. If any limitation within this Bond is prohibited by
                          any law controlling this Bond's construction, such
                          limitation shall be deemed to be amended so as to
                          equal the minimum period of limitation provided by
                          such law.

Change or             16. This Bond or any instrument amending or affecting
Modification              this Bond may not be changed or modified orally. No
                          change in or modification of this Bond shall be
                          effective except when made by written endorsement to
                          this Bond signed by an authorized representative of
                          the COMPANY.

                      If this Bond is for a sole ASSURED, no change or
                      modification which would adversely affect the rights of
                      the ASSURED shall be effective prior to sixty (60) days
                      after written notice has been furnished to the Securities
                      and Exchange Commission, Washington, D.C., by the acting
                      party.

ICAP Bond (5-98)
Form 17-02-1421 (Ed. 5-98) Page 18 of 19


CONDITIONS AND
LIMITATIONS

Change or Modification    If this Bond is for a joint ASSURED, no charge or
(continued)               modification which would adversely affect the rights
                          of the ASSURED shall be effective prior to sixty (60)
                          days after written notice has been furnished to all
                          insured INVESTMENT COMPANIES and to the Securities and
                          Exchange Commission, Washington, D.C., by the a
                          COMPANY.

ICAP Bond (5-98)
Form 17-02-1421 (Ed. 5-98) Page 19 of 19



                              CHUBB & SON, DIV. OF FEDERAL INSURANCE COMPANY
                              AS MANAGER OF THE MEMBER INSURERS OF THE
                              CHUBB GROUP OF INSURANCE COMPANIES

                                  POLICYHOLDER
                              DISCLOSURE NOTICE OF

TERRORISM INSURANCE
COVERAGE
(FOR POLICIES WITH NO TERRORISM EXCLUSION OR SUBLIMIT)

You are hereby notified that, under the Terrorism Risk Insurance Act of 2002
(the "Act") effective November 26, 2002, this policy makes available to you
insurance for losses arising out of certain acts of international terrorism.
Terrorism is defined as any act certified by the Secretary of the Treasury, in
concurrence with the Secretary of State and the Attorney General of the United
States, to be an act of terrorism; to be a violent act or an act that is
dangerous to human life, property or infrastructure; to have resulted in damage
within the United States, or outside the United States in the case of an air
carrier or vessel or the premises of a United States Mission; and to have been
committed by an individual or individuals acting on behalf of any foreign person
or foreign interest, as part of an effort to coerce the civilian population of
the United States or to influence the policy or affect the conduct of the United
States Government by coercion.

You should know that the insurance provided by your policy for losses caused by
acts of terrorism is partially reimbursed by the United States under the formula
set forth in the Act. Under this formula, the United States pays 90% of covered
terrorism losses that exceed the statutorily established deductible to be paid
by the insurance company providing the coverage. The portion of your policy's
annual premium that is attributable to insurance for such acts of terrorism is:
$ -0-.

If you have any questions about this notice, please contact your agent or
broker.

Form 10-02-1281 (Ed. 1/2003)


                               IMPORTANT NOTICE:

THE SEC REQUIRES PROOF OF YOUR FIDELITY INSURANCE POLICY

Your company is now required to file an electronic copy of your fidelity
insurance coverage (Chubb's ICAP Bond policy) to the Securities and Exchange
Commission (SEC), according to rules adopted by the SEC on June 12, 2006.

Chubb is in the process of providing your agent/broker with an electronic copy
of your insurance policy as well as instructions on how to submit this proof of
fidelity insurance coverage to the SEC. You can expect to receive this
information from your agent/broker shortly.

The electronic copy of your policy is provided by Chubb solely as a convenience
and does not affect the terms and conditions of coverage as set forth in the
paper policy you receive by mail. The terms and conditions of the policy mailed
to you, which are the same as those set forth in the electronic copy, constitute
the entire agreement between your company and Chubb.

If you have any questions, please contact your agent or broker.

Form 14-02-12160 (ed. 7/2006)



                       IMPORTANT NOTICE TO POLICYHOLDERS

      All of the members of the Chubb Group of Insurance companies doing
business in the United States (hereinafter "Chubb") distribute their products
through licensed insurance brokers and agents ("producers"). Detailed
information regarding the types of compensation paid by Chubb to producers on US
insurance transactions is available under the Producer Compensation link located
at the bottom of the page at www.chubb.com, or by calling 1-866-588-9478.
Additional information may be available from your producer.

      Thank you for choosing Chubb.

10-02-1295 (ed. 5/2007)



                                                               ENDORSEMENT/RIDER

Effective date of
this endorsement/rider: October 1, 2007         FEDERAL INSURANCE COMPANY
                                                Endorsement/Rider No.   1
                                                To be attached to and
                                                form a part of Bond No. 81905981

Issued to: ING FAMILY OF FUNDS

      DELETING VALUATION-OTHER PROPERTY AND AMENDING CHANGE OR MODIFICATION
                                   ENDORSEMENT

In consideration of the premium charged, it is agreed that this Bond is amended
as follows:

1.    The paragraph titled Other Property in Section 9, Valuation, is deleted in
      its entirety.

2.    The third paragraph in Section 16, Change or Modification, is deleted in
      its entirety and replaced with the following:

      If this Bond is for a joint ASSURED, no change or modification which would
      adversely affect the rights of the ASSURED shall be effective prior to
      sixty (60) days after written notice has been furnished to all insured
      INVESTMENT COMPANIES and the Securities and Exchange Commission,
      Washington, D.C., by the COMPANY.

The title and any headings in this endorsement/rider are solely for convenience
and form no part of the terms and conditions of coverage.

All other terms, conditions and limitations of this Bond shall remain unchanged.

                                   [GRAPHICS]
17-02-2437 (12/2006) rev. Page 1



                                                      FEDERAL INSURANCE COMPANY
                                                      Endorsement No:   2
                                                      Bond Number:      81905981

NAME OF ASSURED: ING FAMILY OF FUNDS

                       ARKANSAS NOTIFICATION ENDORSEMENT

It is agreed that this Bond is amended by adding to Section 13., Termination,
the following:

"No cancellation or termination of this Bond as an entirety, whether by or at
the request of the ASSURED or by the COMPANY, shall take effect prior to the
expiration of thirty (30) days after written notice of such cancellation or
termination has been filed with the Arkansas Securities Commissioner, Arkansas
Securities Division, Heritage West Building, 3rd Floor, 201 East Markham, Little
Rock, Arkansas 72201 unless an earlier date of such cancellation or termination
is approved by said Arkansas Securities Department, State of Arkansas."

This Endorsement applies to loss discovered after 12:01 a.m. on October 1, 2007.

ALL OTHER TERMS AND CONDITIONS OF THIS BOND REMAIN UNCHANGED.

Date: October 18, 2007

[GRAPHICS]

State Amendatory - General Use Form 17-02-1343 (Rev. 1-97)



                                                      FEDERAL INSURANCE COMPANY
                                                      Endorsement No:   3
                                                      Bond Number:      81905981

NAME OF ASSURED: ING FAMILY OF FUNDS

                          NAME OF ASSURED ENDORSEMENT

It is agreed that the NAME OF ASSURED in the DECLARATIONS is amended to read as
follows:

ING FAMILY OF FUNDS

ING CORPORATE LEADERS TRUST
      ING Corporate Leaders Trust Fund

ING EQUITY TRUST
      ING Financial Services Fund
      ING Fundamental Research Fund
      ING LargeCap Growth Fund
      ING LargeCap Value Fund
      ING MidCap Opportunities Fund
      ING Value Choice Fund
      ING Opportunistic LargeCap Fund
      ING Index Plus LargeCap Equity Fund (Formerly PPF 1)
      ING Index Plus LargeCap Equity Fund II (Formerly PPF 2)
      ING Index Plus LargeCap Equity Fund III (Formerly PPF 3)
      ING Principal Protection Fund IV
      ING Principal Protection Fund V
      ING Principal Protection Fund VI
      ING Principal Protection Fund VII
      ING Principal Protection Fund VIII
      ING Principal Protection Fund IX
      ING Principal Protection Fund X
      ING Principal Protection Fund XI
      ING Principal Protection Fund XII
      ING Real Estate Fund
      ING SmallCap Opportunities Fund
      ING SmallCap Value Choice Fund

ING FUNDS TRUST
      ING Classic Money Market Fund
      ING GNMA Income Fund
      ING High Yield Bond Fund
      ING Institutional Prime Money Market Fund
      ING Intermediate Bond Fund
      ING National Tax-Exempt Bond Fund

ING MUTUAL FUNDS
      ING Disciplined International SmallCap Fund
      ING Diversified International Fund
      ING Emerging Countries Fund
ICAP Bond

Form 17-02-0949 (Rev. 1-97)                 Page 1



      ING Emerging Markets Fixed Income Fund
      ING Foreign Fund
      ING Global Bond Fund
      ING Global Equity Dividend Fund
      ING Global Real Estate Fund
      ING Global Value Choice Fund
      ING Greater China Fund
      ING Index Plus International Equity Fund
      ING International Capital Appreciation Fund
      ING International Equity Dividend Fund
      ING International Real Estate Fund
      ING International SmallCap Fund
      ING International Value Choice Fund
      ING Global Natural Resources Fund (formerly ING Precious Metals Fund)
      ING Russia Fund
      ING International Growth Opportunities Fund
      ING International Value Opportunities Fund
      ING MAYFLOWER TRUST
      ING International Value Fund

ING INVESTMENT FUNDS, INC.
      ING MagnaCap Fund

ING SEPARATE PORTFOLIOS TRUST
      ING Sports Core Fixed Income Fund
      ING Sports Core Plus Fixed Income Fund

ING PRIME RATE TRUST
      ING Prime Rate Trust

ING SENIOR INCOME FUND
      ING Senior Income Fund

ING ASIA PACIFIC HIGH DIVIDEND EQUITY INCOME FUND
      ING Asia Pacific High Dividend Equity Income Fund

ING GLOBAL EQUITY DIVIDEND AND PREMIUM OPPORTUNITY FUND
      ING Global Equity Dividend and Premium Opportunity Fund

ING GLOBAL ADVANTAGE AND PREMIUM OPPORTUNITY FUND
      ING Global Advantage and Premium Opportunity Fund

ING RISK MANAGED NATURAL RESOURCES FUND
      ING Risk Managed Natural Resources Fund

ING VP NATURAL RESOURCES TRUST
      ING VP Natural Resources Trust

ICAP Bond
Form 17-02-0949 (Ed. 1-97)                 Page 2



ING VARIABLE INSURANCE TRUST
      ING VP Global Equity Dividend Portfolio
      ING GET U.S. Core Portfolio - Series 1
      ING GET U.S. Core Portfolio - Series 2
      ING GET U.S. Core Portfolio - Series 3
      ING GET U.S. Core Portfolio - Series 4
      ING GET U.S. Core Portfolio - Series 5
      ING GET U.S. Core Portfolio - Series 6
      ING GET U.S. Core Portfolio - Series 7
      ING GET U.S. Core Portfolio - Series 8
      ING GET U.S. Core Portfolio - Series 9
      ING GET U.S. Core Portfolio - Series 10
      ING GET U.S. Core Portfolio - Series 11
      ING GET U.S. Core Portfolio - Series 12
      ING GET U.S. Core Portfolio - Series 13
      ING GET U.S. Core Portfolio - Series 14

ING VARIABLE PRODUCTS TRUST
      ING VP Financial Services Portfolio
      ING VP High Yield Bond Portfolio
      ING VP International Value Portfolio
      ING VP MidCap Opportunities Portfolio
      ING VP Real Estate Portfolio
      ING VP SmallCap Opportunities Portfolio

ING INVESTORS TRUST
      ING AllianceBernstein Mid Cap Growth Portfolio
      ING American Funds Growth-Income Portfolio
      ING American Funds Growth Portfolio
      ING American Funds International Portfolio
      ING BlackRock Inflation Protected Bond Portfolio
      ING BlackRock Large Cap Growth Portfolio
      ING BlackRock Large Cap Value Portfolio
      ING Capital Guardian U.S. Equities Portfolio
      ING Disciplined Small Cap Value Portfolio
      ING EquitiesPlus Portfolio
      ING Evergreen Health Sciences Portfolio
      ING Evergreen Omega Portfolio
      ING FMR Diversified Mid Cap Portfolio
      ING FMR Large Cap Growth Portfolio
      ING FMR Mid Cap Growth Portfolio
      ING Franklin Income Fund
      ING Franklin Mutual Shares Portfolio
      ING Franklin Templeton Founding Strategy Portfolio
      ING Global Real Estate Portfolio
      ING Global Resources Portfolio
      ING Global Technology Portfolio
      ING International Growth Opportunities Portfolio
      ING Janus Contrarian Portfolio
      ING JPMorgan Emerging Markets Equity Portfolio
      ING JPMorgan Small Cap Core Equity Portfolio
      ING JPMorgan Value Opportunities Portfolio
      ING Julius Baer Foreign Portfolio
      ING Legg Mason Value Portfolio
      ING Lifestyle Aggressive Growth Portfolio
      ING Lifestyle Growth Portfolio
      ING Lifestyle Moderate Growth Portfolio

ICAP Bond
Form 17-02-0949 (Ed. 1-97)                 Page 3



      ING Lifestyle Moderate Portfolio
      ING Limited Maturity Bond Portfolio
      ING Liquid Assets Portfolio
      ING Lord Abbett Affiliated Portfolio
      ING MarketPro Portfolio
      ING MarketStyle Growth Portfolio
      ING MarketStyle Moderate Growth Portfolio
      ING MarketStyle Moderate Portfolio
      ING Marsico Growth Portfolio
      ING Marsico International Opportunities Portfolio
      ING MFS Total Return Portfolio
      ING MFS Utilities Portfolio
      ING Oppenheimer Main Street Portfolio
      ING PIMCO Core Bond Portfolio
      ING PIMCO High Yield Portfolio
      ING Pioneer Equity Income Portfolio
      ING Pioneer Fund Portfolio
      ING Pioneer Mid Cap Value Portfolio
      ING Stock Index Portfolio
      ING T. Rowe Price Capital Appreciation Portfolio
      ING T. Rowe Price Equity Income Portfolio
      ING Templeton Global Growth Portfolio
      ING UBS U.S. Allocation Portfolio
      ING Van Kampen Capital Growth Portfolio
      ING Van Kampen Global Franchise Portfolio
      ING Van Kampen Growth and Income Portfolio
      ING Van Kampen Real Estate Portfolio
      ING VP Index Plus International Equity Portfolio
      ING Wells Fargo Disciplined Value Portfolio
      ING Wells Fargo Small Cap Disciplined Portfolio

ING PARTNERS, INC.
      ING American Century Large Company Value Portfolio
      ING American Century Small-Mid Cap Value Portfolio
      ING Baron Asset Portfolio
      ING Baron Small Cap Growth Portfolio
      ING Columbia Small Cap Value II Portfolio
      ING Davis Venture Value Portfolio
      ING Fidelity VIP Contrafund Portfolio
      ING Fidelity VIP Equity-Income Portfolio
      ING Fidelity VIP Growth Portfolio
      ING Fidelity VIP Mid Cap Portfolio
      ING Fundamental Research Portfolio
      ING JPMorgan International Portfolio
      ING JPMorgan Mid Cap Value Portfolio
      ING Legg Mason Partners Aggressive Growth Portfolio
      ING Legg Mason Partners Large Cap Growth Portfolio
      ING Lord Abbett U.S. Government Securities Portfolio
      ING Neuberger Berman Partners Portfolio
      ING Neuberger Berman Regency Portfolio
      ING OpCap Balanced Value Portfolio
      ING Oppenheimer Global Portfolio
      ING Oppenheimer Strategic Income Portfolio
      ING PIMCO Total Return Portfolio
      ING Pioneer High Yield Portfolio
      ING Solution 2015 Portfolio
      ING Solution 2025 Portfolio

ICAP Bond
Form 17-02-0949 (Ed. 1-97)                 Page 4



      ING Solution 2035 Portfolio
      ING Solution 2045 Portfolio
      ING Solution Growth and Income Portfolio
      ING Solution Growth Portfolio
      ING Solution Income Portfolio
      ING T. Rowe Price Diversified Mid Cap Portfolio
      ING T. Rowe Price Growth Equity Portfolio
      ING Templeton Foreign Equity Portfolio
      ING Thornburg Value Portfolio
      ING UBS U.S. Large Cap Equity Portfolio
      ING UBS U.S. Small Cap Growth Portfolio
      ING Van Kampen Comstock Portfolio
      ING Van Kampen Equity and Income Portfolio

This Endorsement applies to loss discovered after 12:01 a.m. on October 1, 2007.

ALL OTHER TERMS AND CONDITIONS OF THIS BOND REMAIN UNCHANGED.

Date: October 18, 2007

[GRAPHICS]
ICAP Bond
Form 17-02-0949 (Ed. 1-97)                 Page 5


                                                 FEDERAL INSURANCE COMPANY
                                                 Endorsement No: 4
                                                 Bond Number:    81905981

NAME OF ASSURED: ING FAMILY OF FUNDS

                       AMEND NAME OF ASSURED ENDORSEMENT

It is agreed that NAME OF ASSURED of the DECLARATIONS for this Bond is amended
to include the following:

Any Investment Company registered under the Investment Company Act of 1940 and
created during the Bond Period

This Endorsement applies to loss discovered after 12:01 a.m. on October 1, 2007.

ALL OTHER TERMS AND CONDITIONS OF THIS BOND REMAIN UNCHANGED.

Date: October 18, 2007

[GRAPHIC]
ICAP Bond
Form 17-02-6272 (Ed. 8-04)        Page 1



                                                 FEDERAL INSURANCE COMPANY
                                                 Endorsement No: 5
                                                 Bond Number:   81905981
NAME OF ASSURED: ING FAMILY OF FUNDS

                               PREMIUM ENDORSEMENT

It is agreed that:

1.   The premium for this Bond for the period October 1, 2007 to October 1, 2008
     is:

     Premium: Eighty Five Thousand Dollars ($85,000.00)

2.   It is further agreed that this premium is subject to change during this
     period if amendments are made to this Bond at the request of the ASSURED.

This Endorsement applies to loss discovered after 12:01 a.m. on October 1, 2007.

ALL OTHER TERMS AND CONDITIONS OF THIS BOND REMAIN UNCHANGED.

Date: October 18, 2007

[GRAPHIC]

ICAP Bond

Form 17-02-0735 (Rev. 1-97)



                                                 FEDERAL INSURANCE COMPANY
                                                 Endorsement No: 6
                                                 Bond Number: 81905981

NAME OF ASSURED: ING FAMILY OF FUNDS

                         GENERAL TERMINATION ENDORSEMENT

It is agreed that this Bond is amended by adding to Section 13., Termination,
the following:

No termination of this Bond as an entirety by the COMPANY shall take effect
prior to the expiration of ninety (90) days after written notice of such
termination has been mailed to:

     Midwest Stock Exchange

     Commissioner of Securities, Office of the Secretary of State, Securities
     Division, 8th Floor, Truman State Office Building, Jefferson City, Missouri
     65101.

If the Bond as an entirety terminates based on the occurrence of any of the
events described in a., b., or c. of the third paragraph of this Section 13.,
the COMPANY shall endeavor to provide written notice as soon as practicable of
such termination to:

     Midwest Stock Exchange

     Commissioner of Securities, Office of the Secretary of State, Securities
     Division, 8th Floor,

     Truman State Office Building, Jefferson City, Missouri 65101.

This Endorsement applies to loss discovered after 12:01 a.m. on October 1, 2007.

ALL OTHER TERMS AND CONDITIONS OF THIS BOND REMAIN UNCHANGED.

Date: October 18, 2007

[GRAPHIC]

ICAP Bond
Form 17-02-7052 (Ed. 4-05) Page 1



                                                 FEDERAL INSURANCE COMPANY
                                                 Endorsement No.: 7
                                                 Bond Number:   81905981

NAME OF ASSURED: ING FAMILY OF FUNDS

                           CLAIMS EXPENSE ENDORSEMENT

It is agreed that this Bond is amended as follows:

1.   By adding the following INSURING CLAUSE:

     12.  Claims Expense

               Reasonable expense incurred by the ASSURED, solely for
               independent firms or individuals to determine the amount of loss
               where:

     (1)  the loss is covered under the Bond, and

     (2)  the loss is in excess of the applicable DEDUCTIBLE AMOUNT.

2.   Under General Exclusions-Applicable To All Insuring Clauses, Section 2.f.
     does not apply to loss covered under this INSURING CLAUSE.

This Endorsement applies to loss discovered after 12:01 a.m. on October 1, 2007.

ALL OTHER TERMS AND CONDITIONS OF THIS BOND REMAIN UNCHANGED.

Date: October 18, 2007

[GRAPHIC]

ICAP Bond

Form 17-02-6282 (Ed. 11-04)



Effective date of
this endorsement: October 1, 2007      FEDERAL INSURANCE COMPANY
                                       Endorsement No.: 8
                                       To be attached to and form a part of Bond
                                       Number: 81905981

Issued to: ING FAMILY OF FUNDS

              COMPLIANCE WITH APPLICABLE TRADE SANCTION LAWS RIDER

It is agreed that this insurance does not apply to the extent that trade or
economic sanctions or other laws or regulations prohibit the coverage provided
by this insurance.

ALL OTHER TERMS AND CONDITIONS OF THIS BOND REMAIN UNCHANGED.

Date: October 18, 2007

[GRAPHIC]

Form 14-02-9228 (Ed. 4/2004)



                                                 FEDERAL INSURANCE COMPANY
                                                 Endorsement No.: 9
                                                 Bond Number:     81905981

NAME OF ASSURED: ING FAMILY OF FUNDS

             STOP PAYMENT ORDER OR REFUSAL TO PAY CHECK ENDORSEMENT

It is agreed that this Bond is amended as follows:

1.   By adding the following INSURING CLAUSE:

     13. Stop Payment Order or Refusal to Pay Check

          Loss resulting directly from the ASSURED being legally liable to pay
          compensatory damages for:

          a.   complying or failing to comply with notice from any customer of
               the ASSURED or any authorized representative of such customer, to
               stop payment on any check or draft made or drawn upon or against
               the ASSURED by such customer or by any authorized representative
               of such customer, or

          b.   refusing to pay any check or draft made or drawn upon or against
               the ASSURED by any customer of the ASSURED or by any authorized
               representative of such customer.

2.   By adding the following Specific Exclusion:

     Section 4.A. Specific Exclusions : Applicable to INSURING CLAUSE 13

     THIS BOND DOES NOT DIRECTLY OR INDIRECTLY COVER:

     a.   liability assumed by the ASSURED by agreement under any contract,
          unless such liability would have attached to the ASSURED even in the
          absence of such agreement,

     b.   loss arising out of:

          (1)  libel, slander, wrongful entry, eviction, defamation, false
               arrest, false imprisonment, malicious prosecution, assault or
               battery,

          (2)  sickness, disease, physical bodily harm, mental or emotional
               distress or anguish, or death of any person, or

          (3)  discrimination.

This Endorsement applies to loss discovered after 12:01 a.m. on October 1, 2007.

ALL OTHER TERMS AND CONDITIONS OF THIS BOND REMAIN UNCHANGED.

Date: October 18, 2007

[GRAPHIC]

ICAP Bond

Form 17-02-2365 (Ed. 10-00)



                                                 FEDERAL INSURANCE COMPANY
                                                 Endorsement No.: 10
                                                 Bond Number:     81905981

NAME OF ASSURED: ING FAMILY OF FUNDS

                      EXTENDED COMPUTER SYSTEMS ENDORSEMENT

It is agreed that this Bond is amended as follows:

1.   By adding the following INSURING CLAUSE:

     14.  Extended Computer Systems

          A. Electronic Data, Electronic Media, Electronic Instruction

               Loss resulting directly from:

     (1)  the fraudulent modification of ELECTRONIC DATA, ELECTRONIC MEDIA or
          ELECTRONIC INSTRUCTION being stored within or being run within any
          system covered under this INSURING CLAUSE,

     (2)  robbery, burglary, larceny or theft of ELECTRONIC DATA, ELECTRONIC
          MEDIA or ELECTRONIC INSTRUCTIONS,

     (3)  the acts of a hacker causing damage or destruction of ELECTRONIC DATA,
          ELECTRONIC MEDIA or ELECTRONIC INSTRUCTION owned by the ASSURED or for
          which the ASSURED is legally liable, while stored within a COMPUTER
          SYSTEM covered under this INSURING CLAUSE, or

     (4)  the damage or destruction of ELECTRONIC DATA, ELECTRONIC MEDIA or
          ELECTRONIC INSTRUCTION owned by the ASSURED or for which the ASSURED
          is legally liable while stored within a COMPUTER SYSTEM covered under
          INSURING CLAUSE 14, provided such damage or destruction was caused by
          a computer program or similar instruction which was written or altered
          to intentionally incorporate a hidden instruction designed to damage
          or DESTROY ELECTRONIC DATA, ELECTRONIC MEDIA, or ELECTRONIC
          INSTRUCTION in the COMPUTER SYSTEM in which the computer program or
          instruction so written or so altered is used.

ICAP2 Bond
Form 17-02-2976 (Ed. 1-02) Page 1



B.   Electronic Communication

     Loss resulting directly from the ASSURED having transferred, paid or
     delivered any funds or property, established any credit, debited any
     account or given any value on the faith of any electronic communications
     directed to the ASSURED, which were transmitted or appear to have been
     transmitted through:

     (1)  an ELECTRONIC COMMUNICATION SYSTEM,

     (2)  an automated clearing house or custodian, or

     (3)  a Telex, TWX, or similar means of communication,

     directly into the ASSURED'S COMPUTER SYSTEM or COMMUNICATION TERMINAL, and
     fraudulently purport to have been sent by a customer, automated clearing
     house, custodian, or financial institution, but which communications were
     either not sent by said customer, automated clearing house, custodian, or
     financial institution, or were fraudulently modified during physical
     transit of ELECTRONIC MEDIA to the ASSURED or during electronic
     transmission to the ASSURED'S COMPUTER SYSTEM or COMMUNICATION TERMINAL.

C.   Electronic Transmission

     Loss resulting directly from a customer of the ASSURED, any automated
     clearing house, custodian, or financial institution having transferred,
     paid or delivered any funds or property, established any credit, debited
     any account or given any value on the faith of any electronic
     communications, purporting to have been directed by the ASSURED to such
     customer, automated clearing house, custodian, or financial institution
     initiating, authorizing, or acknowledging, the transfer, payment, delivery
     or receipt of funds or property, which communications were transmitted
     through:

     (1)  an ELECTRONIC COMMUNICATION SYSTEM,

     (2)  an automated clearing house or custodian, or

     (3)  a Telex, TWX, or similar means of communication,

     directly into a COMPUTER SYSTEM or COMMUNICATION TERMINAL of said customer,
     automated clearing house, custodian, or financial institution, and
     fraudulently purport to have been directed by the ASSURED, but which
     communications were either not sent by the ASSURED, or were fraudulently
     modified during physical transit of ELECTRONIC MEDIA from the ASSURED or
     during electronic transmission from the ASSURED'S Computer System or
     COMMUNICATION TERMINAL, and for which loss the ASSURED is held to be
     legally liable.

ICAP2 Bond
Form 17-02-2976 (Ed. 1-02) Page 2



2.   By adding to Section 1., Definitions, the following:

     r.   COMMUNICATION TERMINAL means a teletype, teleprinter or video display
          terminal, or similar device capable of sending or receiving
          information electronically. Communication Terminal does not mean a
          telephone.

     s.   ELECTRONIC COMMUNICATION SYSTEM means electronic communication
          operations by Fedwire, Clearing House Interbank Payment System
          (CHIPS), Society of Worldwide International Financial
          Telecommunication (SWIFT), similar automated interbank communication
          systems, and Internet access facilities.

     t.   ELECTRONIC DATA means facts or information converted to a form usable
          in COMPUTER SYSTEMS and which is stored on ELECTRONIC MEDIA for use by
          computer programs.

     u.   ELECTRONIC INSTRUCTION means computer programs converted to a form
          usable in a COMPUTER SYSTEM to act upon ELECTRONIC DATA.

     v.   ELECTRONIC MEDIA means the magnetic tape, magnetic disk, optical disk,
          or any other bulk media on which data is recorded.

3.   By adding the following Section after Section 4., Specific
     Exclusions-Applicable to All INSURING CLAUSES except 1., 4., and 5.:

     Section 4.A. Specific Exclusions-Applicable to INSURING CLAUSE 14

     THIS BOND DOES NOT DIRECTLY OR INDIRECTLY COVER:

     a.   loss resulting directly or indirectly from FORGED, altered or
          fraudulent negotiable instruments, securities, documents or written
          instruments used as source documentation in the preparation of
          ELECTRONIC DATA;

     b.   loss of negotiable instruments, securities, documents or written
          instruments except as converted to ELECTRONIC DATA and then only in
          that converted form;

     c.   loss resulting from mechanical failure, faulty construction, error in
          design, latent defect, wear or tear, gradual deterioration, electrical
          disturbance, ELECTRONIC MEDIA failure or breakdown or any malfunction
          or error in programming or error or omission in processing;

     d.   loss resulting directly or indirectly from the input of ELECTRONIC
          DATA at an authorized electronic terminal of an ELECTRONIC FUNDS
          TRANSFER SYSTEM or a CUSTOMER COMMUNICATION SYSTEM by a person who had
          authorized access from a customer to that customer's authentication
          mechanism; or

     e.   liability assumed by the ASSURED by agreement under any contract,
          unless such liability would have attached to the ASSURED even in the
          absence of such agreement; or

     f.   loss resulting directly or indirectly from:

          (1)  written instruction unless covered under this INSURING CLAUSE; or

          (2)  instruction by voice over the telephone, unless covered under
               this INSURING CLAUSE.

ICAP2 Bond
Form 17-02-2976 (Ed. 1-02) Page 3



4.   By adding to Section 9., Valuation, the following:

     Electronic Data, Electronic Media, Or Electronic Instruction

     In case of loss of, or damage to, ELECTRONIC DATA, ELECTRONIC MEDIA or
     ELECTRONIC INSTRUCTION used by the ASSURED in its business, the COMPANY
     shall be liable under this Bond only if such items are actually reproduced
     form other ELECTRONIC DATA, ELECTRONIC MEDIA or ELECTRONIC INSTRUCTION of
     the same kind or quality and then for not more than the cost of the blank
     media and/or the cost of labor for the actual transcription or copying of
     data which shall have been furnished by the ASSURED in order to reproduce
     such ELECTRONIC DATA, ELECTRONIC MEDIA or ELECTRONIC INSTRUCTION subject to
     the applicable SINGLE LOSS LIMIT OF LIABILITY.

     However, if such ELECTRONIC DATA can not be reproduced and said ELECTRONIC
     DATA REPRESENTS SECURITIES or financial instruments having a value, then
     the loss will be valued as indicated in the SECURITIES and OTHER PROPERTY
     paragraphs of this Section.

This Endorsement applies to loss discovered after 12:01 a.m. on October 1, 2007.

ALL OTHER TERMS AND CONDITIONS OF THIS BOND REMAIN UNCHANGED.

Date: October 18, 2007

[GRAPHIC]

ICAP2 Bond
Form 17-02-2976 (Ed. 1-02) Page 4



                                                 FEDERAL INSURANCE COMPANY
                                                 Endorsement No.: 11
                                                 Bond Number:     81905981

NAME OF ASSURED: ING FAMILY OF FUNDS

                           AMEND DISCOVERY ENDORSEMENT

It is agreed that this Bond is amended by deleting Section 6., Discovery, in its
entirety and substituting the following:

6.   Discovery

     This Bond applies only to loss first discovered by the Risk Management
     Department, Senior Vice President, or above of the ASSURED during the BOND
     PERIOD. Discovery occurs at the earlier of the Risk Management Department,
     Senior Vice President, or above of the ASSURED being aware of:

     a. facts which may subsequently result in a loss of a type covered by this
     Bond, or

     b. an actual or potential claim in which it is alleged that the ASSURED is
     liable to a third party, regardless of when the act or acts causing or
     contributing to such loss occurred, even though the amount of loss does not
     exceed the applicable DEDUCTIBLE AMOUNT, or the exact amount or details of
     loss may not then be known.

This Endorsement applies to loss discovered after 12:01 a.m. on October 1, 2007.

ALL OTHER TERMS AND CONDITIONS OF THIS BOND REMAIN UNCHANGED.

Date: October 18, 2007

[GRAPHIC]

ICAP Bond

Form 17-02-6260 (Ed. 6-04)



                                                               ENDORSEMENT/RIDER
Effective date of
this endorsement/rider: October 1, 2007    FEDERAL INSURANCE COMPANY
                                           Endorsement/Rider No.     12
                                           To be attached to and
                                           form a part of Bond No.   81905981

Issued to: ING FAMILY OF FUNDS

                       AMEND NOTICE TO COMPANY ENDORSEMENT

In consideration of the premium charged, it is agreed Section 7., Notice to
Company-Proof-Legal Proceedings Against Company, of the Conditions and
Limitations, is amended by deleting paragraph a. and replacing it with the
following:

     a.   The Risk Management Department, Senior Vice President, or above of the
          ASSURED shall give the COMPANY notice thereof at the earliest
          practicable moment, not to exceed ninety (90) days after discovery of
          loss, in an amount that is in excess of 50% of the applicable
          DEDUCTIBLE AMOUNT, as stated in ITEM 2. of the DECLARATIONS.

The title and any headings in this endorsement/rider are solely for convenience
and form no part of the terms and conditions of coverage.

All other terms, conditions and limitations of this Bond shall remain unchanged.

                                [GRAPHIC]

Q07-2394 (10/2007) Page 1


                  APPROVAL OF INVESTMENT COMPANY BLANKET BOND
                            INSURANCE POLICY RENEWAL

PROPOSED RESOLUTIONS

      RESOLVED, that it is the determination of the Directors/Trustees,
including a majority of those Directors/Trustees who are not parties to the
Investment Company Blanket Bond insurance (the "17g-1 Bond") written by Chubb
Group of Insurance Companies, nor "interested persons" as defined by the
Investment Company Act of 1940 (the "1940 Act") of any such party, that the
17g-1 Bond insuring each and all of the ING Funds (the "Funds") for covered acts
and omissions of their respective officers and Directors/Trustees and the
officers and employees of ING Investments, LLC and Directed Services, LLC and
their affiliates, in accordance with the requirements of Rule 17g-1 promulgated
by the SEC under 17(g) of the 1940 Act, is reasonable in form and amount after
having given due consideration to all relevant factors, including, but not
limited to, the value of the aggregate assets of each of the Funds to which any
such covered person may have access, the type and terms of the arrangements made
for the custody and safekeeping of such assets, the nature of the securities in
each of the Fund's portfolios, the number of other parties named as insured
parties under the Bonds, and the nature of the business activities of such other
parties; and

      FURTHER RESOLVED, that the terms of the 17g-1 Bond as presented at this
Meeting, be, and hereby is, continued until October 1, 2008, for and on behalf
of each of the Funds, with such changes as the officers may deem necessary as a
result of negotiations with the Insurance Company, provided such changes are in
accord with the requirements of Rule 17g-1; and

      FURTHER RESOLVED, that the Directors/Trustees, including a majority of
those Directors/Trustees who are not parties to the 17g-1 Bond nor "interested
persons" as defined in the 1940 Act of any such party, hereby approve the
continued payment by ING Investments, LLC and Directed Services, LLC for
pro-rata share of each of the Funds, as applicable, based on assets of the
respective covered funds, of the projected premium for coverage under the 17g-1
Bond, having given due consideration to all relevant factors, including, but not
limited to, the number of other parties named as insured parties under the
Bonds, the nature of the business activities of such other parties, the amount
of the Bonds, the amount of the projected premium for the Bonds, the ratable
allocation of the projected premium among all the parties named as insureds, and
the extent to which the share of the projected premium allocated to each of the
Funds is less than the projected premium that any individual Fund would have
had to pay if it had provided and maintained a single insured bond.


                                   EXHIBIT A

                             ING FUNDS SERVICES, LLC
                             FIDELITY BOND ANALYSIS
                                  JULY 17, 2007



                                                                                           GROSS                   MINIMUM
                                                                                         ASSET SIZE                BONDING
NAME OF FUND                                                                           CLASSIFICATION            REQUIREMENT
------------                                                                           --------------            -----------
                                                                                                        
ING CORPORATE LEADERS TRUST                                   $   457,770,357   250,000,000 to 500,000,000          750,000
                                                              ---------------
    ING Corporate Leaders Trust Fund                          $   457,770,357

ING EQUITY TRUST                                              $ 5,911,294,585   over 4,000,000,000                2,500,000
                                                              ---------------
    ING Financial Services Fund                               $ 2,983,352,914
    ING Fundamental Research Fund                             $    39,501,060
    ING LargeCap Growth Fund                                  $   255,964,388
    ING LargeCap Value Fund                                   $   111,253,052
    ING MidCap Opportunities Fund                             $   295,595,548
    ING Value Choice Fund                                     $   360,552,610
    ING Opportunistic LargeCap Fund                           $     8,388,671
    ING Index Plus LargeCap Equity Fund (Formerly PPF 1)      $    44,868,541
    ING Index Plus LargeCap Equity Fund II (Formerly PPF 2)   $    70,174,654
    ING Index Plus LargeCap Equity Fund II (Formerly PPF 3)   $    68,737,433
    ING Principal Protection Fund IV                          $   307,224,167
    ING Principal Protection Fund V                           $   238,064,808
    ING Principal Protection Fund VI                          $   216,894,227
    ING Principal Protection Fund VII                         $   107,217,996
    ING Principal Protection Fund VIII                        $    65,749,270
    ING Principal Protection Fund IX                          $    50,321,851
    ING Principal Protection Fund X                           $    40,286,610
    ING Principal Protection Fund XI                          $    27,358,716
    ING Principal Protection Fund XII                         $    13,329,341
    ING Real Estate Fund                                      $   349,558,341
    ING SmallCap Opportunities Fund                           $   150,331,490
    ING SmallCap Value Choice Fund                            $   106,568,897

ING FUNDS TRUST                                               $ 4,071,391,895   over 4,000,000,000                2,500,000
                                                              ---------------
    ING Classic Money Market Fund                             $   983,783,486
    ING GNMA Income Fund                                      $   595,493,642
    ING High Yield Bond Fund                                  $   149,846,606
    ING Institutional Prime Money Market Fund                 $ 1,127,889,240
    ING Intermediate Bond Fund                                $ 1,187,249,452
    ING National Tax-Exempt Bond Fund                         $    27,129,469




                                   EXHIBIT A

                                                                                                        
ING MUTUAL FUNDS                                              $ 7,263,272,794   over 4,000,000,000                2,500,000
                                                              ---------------
    ING Disciplined International SmallCap Fund               $   358,553,918
    ING Diversified International Fund                        $   502,087,434
    ING Emerging Countries Fund                               $   325,943,587
    ING Emerging Markets Fixed Income Fund                    $   259,532,096
    ING Foreign Fund                                          $   676,652,407
    ING Global Bond Fund                                      $    27,016,339
    ING Global Equity Dividend Fund                           $   403,614,219
    ING Global Natural Resources                              $   144,999,217
    ING Global Real Estate Fund                               $ 1,429,983,587
    ING Global Value Choice Fund                              $   128,599,622
    ING Greater China Fund                                    $    58,194,849
    ING Index Plus International Equity Fund                  $   103,634,045
    ING International Capital Appreciation Fund               $   122,991,234
    ING International Equity Dividend Fund                    $    10,607,171
    ING International Growth Opportunities Fund               $   139,253,629
    ING International Real Estate Fund                        $   416,817,187
    ING International SmallCap Fund                           $ 1,147,299,279
    ING International Value Choice Fund                       $   111,968,609
    ING International Value Opportunities                     $    10,738,775
    ING Russia Fund                                           $   884,785,590

ING MAYFLOWER TRUST                                           $ 5,666,342,683   over 4,000,000,000                2,500,000
                                                              ---------------
    ING International Value Fund                              $ 5,666,342,683

ING INVESTMENT FUNDS, INC.                                    $   381,067,497   250,000,000 to 500,000,000          750,000
                                                              ---------------
    ING MagnaCap Fund                                         $   381,067,497

ING SEPARATE PORTFOLIOS TRUST                                 $    14,109,781   10,000,000 to 15,000,000            200,000
                                                              ---------------
    ING SPorts Core Fixed Income Fund                         $     4,107,105
    ING Sports Core Plus Fixed Income Fund                    $    10,002,676

ING PRIME RATE TRUST                                          $ 1,899,792,168   1,500,000,000 to 2,000,000,000    1,500,000
                                                              ---------------
    ING Prime Rate Trust                                      $ 1,899,792,168

ING SENIOR INCOME FUND                                        $ 2,327,704,938   2,000,000,000 to 2,500,000,000    1,700,000
                                                              ---------------
    ING Senior Income Fund                                    $ 2,327,704,938

ING ASIA PACIFIC HIGH DIVIDEND EQUITY INCOME FUND             $   330,561,939   250,000,000 to 500,000,000          750,000
                                                              ---------------
    ING Asia Pacific High Dividend Equity Income Fund         $   330,561,939

ING GLOBAL EQUITY DIVIDEND AND PREMIUM OPPORTUNITY FUND       $ 2,001,164,657   2,000,000,000 to 2,500,000,000    1,700,000
                                                              ---------------
    ING Global Equity Dividend and Premium Opportunity Fund   $ 2,001,164,657




                                   EXHIBIT A

                                                                                                         
ING GLOBAL ADVANTAGE AND PREMIUM OPPORTUNITY FUND             $   401,546,229   250,000,000 to 500,000,000          750,000
                                                              ---------------
    ING Global Advantage and Premium Opportunity Fund         $   401,546,229

ING RISK MANANGED NATURUAL RESOURCES FUND                     $   459,708,857   250,000,000 to 500,000,000          750,000
                                                              ---------------
    ING Risk Managed Natural Resources Fund                   $   459,708,857

ING VP NATURAL RESOURCES TRUST                                $   119,198,919   100,000,000 to 150,000,000          525,000
                                                              ---------------
    ING VP Natural Resources Trust                            $   119,198,919

ING VARIABLE INSURANCE TRUST                                  $   936,289,658   750,000,000 to 1,000,000,000      1,000,000
                                                              ---------------
    ING VP Global Equity Dividend Portfolio                   $    61,283,068
    ING GET U.S. Core Portfolio - Series 1                    $   103,323,176
    ING GET U.S. Core Portfolio - Series 2                    $    77,232,189
    ING GET U.S. Core Portfolio - Series 3                    $   108,602,898
    ING GET U.S. Core Portfolio - Series 4                    $    49,712,550
    ING GET U.S. Core Portfolio - Series 5                    $    35,128,884
    ING GET U.S. Core Portfolio - Series 6                    $    71,191,325
    ING GET U.S. Core Portfolio - Series 7                    $    49,826,084
    ING GET U.S. Core Portfolio - Series 8                    $    31,642,749
    ING GET U.S. Core Portfolio - Series 9                    $    24,021,791
    ING GET U.S. Core Portfolio - Series 10                   $    25,514,180
    ING GET U.S. Core Portfolio - Series 11                   $    28,570,424
    ING GET U.S. Core Portfolio - Series 12                   $    52,890,321
    ING GET U.S. Core Portfolio - Series 13                   $    78,809,224
    ING GET U.S. Core Portfolio - Series 14                   $   138,540,795

ING VARIABLE PRODUCTS TRUST                                   $ 1,270,661,552   1,000,000,000 to 1,500,000,000    1,250,000
                                                              ---------------
    ING VP Financial Services Portfolio                       $    88,820,826
    ING VP High Yield Bond Portfolio                          $    88,505,430
    ING VP International Value Portfolio                      $   559,020,298
    ING VP MidCap Opportunities Portfolio                     $   110,143,711
    ING VP Real Estate Portfolio                              $   212,509,199
    ING VP SmallCap Opportunities Portfolio                   $   211,662,088

ING INVESTORS TRUST                                           $47,247,343,053   Over 4,000,000,000                2,500,000
                                                              ---------------
    ING AllianceBernstein Mid Cap Growth Portfolio            $   640,100,874
    ING American Funds Growth -Income Portfolio               $ 1,641,458,449
    ING American Funds Growth Portfolio                       $ 2,376,624,909
    ING American Funds International Portfolio                $ 1,384,986,388
    ING BlackRock Inflation Protected  Bond Portfolio         $   175,868,128
    ING BlackRock Large Cap Growth Portfolio                  $   490,170,561
    ING BlackRock Large Cap Value Portfolio                   $   190,054,358
    ING Capital Guardian U.S Equities Portfolio               $   581,200,039
    ING Disciplined Small Cap Value Portfolio                 $   182,555,254
    ING EquitiesPlus Portfolio                                $   124,516,514
    ING Evergreen Health Sciences Portfolio                   $   216,233,223




                                   EXHIBIT A

                                                                                                        
    ING Evergreen Omega Portfolio                             $   212,739,281
    ING FMR Diversified Mid Cap Portfolio                     $ 1,342,324,086
    ING FMR Large Cap Growth Portfolio                        $   630,959,933
    ING FMR Mid Cap Growth Portfolio                          $   532,298,045
    ING Franklin Income Fund                                  $   380,927,298
    ING Franklin Mutual Shares Portfolio                      $   104,593,067
    ING Franklin Templeton Founding Strategy Portfolio        $   107,520,285
    ING Global Real Estate Portfolio                          $   246,646,267
    ING Global Resources Portfolio                            $   930,341,435
    ING Global Technology Portfolio                           $    97,209,887
    ING International Growth Opportunities Portfolio          $   185,384,141
    ING Janus Contrarian Portfolio                            $   738,469,565
    ING JPMorgan Emerging Markets Equity Portfolio            $ 1,062,797,966
    ING JPMorgan Small Cap Core Equity Portfolio              $   483,225,139
    ING JPMorgan Value Opportunities Portfolio                $   389,174,427
    ING Julius Baer Foreign Portfolio                         $ 2,199,362,863
    ING Legg Mason Value Portfolio                            $   992,139,090
    ING Lifestyle Aggressive Growth Portfolio                 $ 1,396,262,777
    ING Lifestyle Growth Portfolio                            $ 3,541,909,582
    ING Lifestyle Moderate Growth Portfolio                   $ 2,700,917,662
    ING Lifestyle Moderate Portfolio                          $ 1,195,543,923
    ING Limited Maturity Bond Portfolio                       $   676,486,426
    ING Liquid Assets Portfolio                               $ 1,195,888,234
    ING Lord Abbett Affiliated Portfolio                      $   175,983,607
    ING MarketPro Portfolio                                   $    45,376,708
    ING MarketStyle Growth Portfolio                          $    13,819,626
    ING MarketStyle Moderate Growth Portfolio                 $    12,934,125
    ING MarketStyle Moderate Portfolio                        $     4,284,271
    ING Marsico Growth Portfolio                              $   937,117,622
    ING Marsico International Opportunities Portfolio         $   439,676,536
    ING MFS Total Return Portfolio                            $ 1,601,138,632
    ING MFS Utilities Portfolio                               $   491,976,236
    ING Oppenheimer Main Street Portfolio                     $   554,466,128
    ING PIMCO Core Bond Portfolio                             $ 1,524,933,141
    ING PIMCO High Yield Portfolio                            $   745,945,090
    ING Pioneer Equity Income Portfolio                       $     1,099,572
    ING Pioneer Fund Portfolio                                $   136,631,140
    ING Pioneer Mid Cap Value Portfolio                       $   990,668,109
    ING Stock Index Portfolio                                 $   473,579,957
    ING T. Rowe Price Capital Appreciation Portfolio          $ 3,491,630,314
    ING T. Rowe Price Equity Income Portfolio                 $ 1,551,466,537
    ING Templeton Global Growth Portfolio                     $   568,101,822
    ING UBS U.S. Allocation Portfolio                         $   111,548,865
    ING Van Kampen Capital Growth Portfolio                   $   107,681,978
    ING Van Kampen Global Franchise Portfolio                 $   463,188,274
    ING Van Kampen Growth and Income Portfolio                $ 1,110,401,871




                                   EXHIBIT A

                                                                                                        
    ING Van Kampen Real Estate Portfolio                      $ 1,191,689,373
    ING VP Index Plus International Equity Portfolio          $   681,451,751
    ING Wells Fargo Disciplined Value Portfolio               $   280,838,897
    ING Wells Fargo Small Cap Disciplined Portfolio           $   192,822,795

ING PARTNERS, INC.                                            $16,587,238,302   over 4,000,000,000                2,500,000
                                                              ---------------
    ING American Century Large Company Value Portfolio        $   120,275,341
    ING American Century Small-Mid Cap Value Portfolio        $   112,520,141
    ING Baron Asset Portfolio                                 $    28,215,523
    ING Baron Small Cap Growth Portfolio                      $   482,220,525
    ING Columbia Small Cap Value II Portfolio                 $   157,683,210
    ING Davis Venture Value Portfolio                         $   290,350,586
    ING Fidelity VIP Contrafund Portfolio                     $   329,985,563
    ING Fidelity VIP Equity-Income Portfolio                  $    51,035,276
    ING Fidelity VIP Growth Portfolio                         $    27,492,943
    ING Fidelity VIP Mid Cap Portfolio                        $    65,834,167
    ING Fundamental Research Portfolio                        $    93,038,766
    ING JPMorgan International Portfolio                      $   759,687,004
    ING JPMorgan Mid Cap Value Portfolio                      $   288,625,995
    ING Legg Mason Partners Aggressive Growth Portfolio       $ 1,365,849,848
    ING Legg Mason Partners Large Cap Growth Portfolio        $    40,746,731
    ING Lord Abbett U.S. Government Securities Portfolio      $    43,160,580
    ING Neuberger Berman Partners Portfolio                   $   454,369,830
    ING Neuberger Berman Regency Portfolio                    $    21,848,891
    ING OpCap Balanced Value Portfolio                        $    81,032,882
    ING Oppenheimer Global Portfolio                          $ 2,932,729,524
    ING Oppenheimer Strategic Income Portfolio                $   446,999,443
    ING PIMCO Total Return Portfolio                          $   391,001,966
    ING Pioneer High Yield Portfolio                          $   116,879,274
    ING Solution 2015 Portfolio                               $   451,975,127
    ING Solution 2025 Portfolio                               $   683,304,301
    ING Solution 2035 Portfolio                               $   546,490,267
    ING Solution 2045 Portfolio                               $   297,859,821
    ING Solution Growth and Income Portfolio                  $         3,050
    ING Solution Growth Portfolio                             $         3,061
    ING Solution Income Portfolio                             $   138,452,487
    ING T. Rowe Price Diversified Mid Cap Portfolio           $ 1,162,722,965
    ING T. Rowe Price Growth Equity Portfolio                 $ 1,597,246,551
    ING Templeton Foreign Equity Portfolio                    $   106,323,295
    ING Thornburg Value Portfolio                             $   221,850,023
    ING UBS U.S. Large Cap Equity Portfolio                   $   469,950,416
    ING UBS U.S. Small Cap Growth Portfolio                   $    33,620,464
    ING Van Kampen Comstock Portfolio                         $ 1,135,437,895
    ING Van Kampen Equity and Income Portfolio                $ 1,040,414,570

                                                                                MINIMUM BOND REQUIREMENT         26,625,000
                                                                                PRESENT COVERAGE                 30,000,000
                                                                                RESERVE                           3,375,000

    TOTAL ASSETS COVERED                                      $97,346,459,864


                              ALLOCATION AGREEMENT

                                 FIDELITY BOND

THIS AGREEMENT made as of this 24th day of May, 2002 by and among any of the
Funds listed on Schedule A and any separate classes thereof and all future
investment companies and any separate classes thereof (the "Funds"), which are
named insureds under a joint liability policy as described below and for which
ING Investments, LLC acts as investment manager are entered into under the
following circumstances:

      A. Section 17(g) of the Investment Company Act of 1940, as amended ("the
1940 Act") provides that the Securities and Exchange Commission ("SEC") is
authorized to require that directors, officers and employees of registered
investment companies be covered under a liability, errors and omissions
insurance policy, and the SEC has promulgated rules and regulations dealing with
this subject ("Rule 17g-l");

      B. The Funds are named as joint insureds under the terms of a joint
insurance policy ("Policy") which insures against illegal profit or gain,
intentional wrongful acts, libel, slander, defamation, ERISA claims, insider
trading, as well as other coverage as outlined in the Policy, by the directors,
officers and employees;

      C. A majority of those members of the Board of Directors/Trustees of each
of the Funds, who are not "interested persons" as defined by Section 2(a)(19) of
the 1940 Act, have given due consideration to all factors relevant to the form,
amount and apportionment of premiums and recoveries under such Policy and the
Board of Directors/Trustees of each Fund has approved the term and amount of the
Policy, the portion of the premium payable by that party, and the manner in
which recovery on the Policy, if any, shall be shared by and among the parties
thereto; and

      D. The Funds now desire to enter into the agreement required by Rule 17g-l
of the 1940 Act to establish the manner in which recovery under the Policy, if
any, shall be shared.



      NOW, THEREFORE, IT IS HEREBY AGREED by and among the parties as follows:

            1. Payment of Premiums.

            Each Fund shall pay a portion of the premium due under the Policy
derived by multiplying the premium by a fraction, (i) the denominator of which
is the total net assets of all the Funds combined and (ii) the numerator of
which is the total net assets of each of the Funds individually. The net assets
of the classes are deemed to be represented by the net assets of their
respective funds. Each of the Funds agrees that the appropriateness of the
allocation of said premium will be determined no less often than annually. No
adjustment of the allocation of said premium will be implemented without
approval of the Boards of each of the Funds.

            2. Allocation of Recoveries

            (a) If more than one of the parties hereto is damaged in a single
loss for which recovery is received under the policy, each such party shall
receive that portion of the recovery which represents the loss sustained by that
party, unless the recovery is inadequate to fully indemnify such party
sustaining loss.

            (b) If the recovery is inadequate to fully indemnify each such party
sustaining a loss, the recovery shall be allocated among such parties as
follows:

                  (i) Each Party sustaining a loss shall be allocated an amount
equal to the lesser of its actual loss or the minimum amount of policy which
would be required to be maintained by such party under a single insured policy
(determined as of the time of loss) in accordance with the provisions of Rule
17g-l.

                  (ii) The remaining portion of the proceeds shall be allocated
to each party sustaining a loss not fully covered by the allocation under
subparagraph (i) in the proportion that each such party's last payment of
premium bears to the sum of the last such premium payments of all such parties.
If such allocation would result in any party which had sustained a loss
receiving a portion of the recovery in excess of the loss actually sustained,
such excess portion shall be allocated among the other parties whose losses
would not be fully indemnified. The allocation shall bear the same proportion as
each such party's last payment of premium bears to the sum of the last premium
payments of all parties entitled to receive a share of the excess. Any
allocation in excess of a loss actually sustained by any such party shall be
reallocated in the same manner.

                                       2


            3. Obligation to Maintain Minimum Coverage.

            Each of the Funds represents and warrants to each of the other
parties hereto that the minimum amount of coverage required of it by Rule 17g-1
as of the date hereof is as reflected in the schedule attached hereto. Each of
the Funds agrees that it will determine, no less than at the end of each
calendar quarter, the minimum amount of coverage which would be required of it
by Rule 17g-1 if a determination with respect to the adequacy of the coverage
were currently being made. In the event that the total amount of the minimum
coverage thus determined exceeds the amount of coverage of the then effective
policy, the Boards of each of the Funds will be notified and will determine
whether it is necessary or appropriate to increase the total amount of coverage
of the policy to an amount not less than the total amount of such minimums, or
to secure such excess coverage for one or more of the parties hereto, which,
when added to the total coverage of the policy, will equal an amount of such
minimums. Unless a Fund elects to terminate this Agreement (pursuant to
Paragraph 4) and its participation in a joint-insured policy, each Fund agrees
to pay its fair portion of the new or additional premium (taking into account
all of the then existing circumstances).

            4. Continuation and Termination. This Agreement shall become
effective on the date first written above, subject to the condition that the
Fund's Board of Directors/Trustees, including a majority of those
Directors/Trustees who are not interested persons (as such term is defined in
the 1940 Act) of the Manager, shall have approved this Agreement. This Agreement
shall supersede all prior agreements relating to an allocation of premium on any
joint insured policy and shall apply to the present liability policy coverage
and any renewal or replacement thereof. It shall continue until terminated by
any party hereto upon the giving of not less than sixty (60) days notice to the
other parties hereto in writing.

            5. Amendments. No provision of this Agreement may be changed,
waived, discharged or terminated orally, but only by an instrument in writing
signed by the party against which enforcement of the change, waiver, discharge
or termination is sought. A written amendment of this Agreement is effective
upon the approval of the Board of Directors/Trustees and the Manager.

                                       3


      IN WITNESS WHEREOF, the parties hereto have caused these presents to be
duly executed by their duly authorized officers as of the date first above
written.

On Behalf of: All ING Funds Listed on Schedule A

By: /s/ Michael J. Roland
    ----------------------------
    Michael J. Roland
    Executive Vice President

                                       4


                               AMENDED SCHEDULE A

                               WITH RESPECT TO THE

                       ALLOCATION AGREEMENT - BLANKET BOND
                                 (MAY 29, 2003)

ING Classic Money Market Fund
ING Convertible Fund
ING Emerging Countries Fund
ING Equity and Bond Fund
ING Financial Services Fund
ING Foreign Fund
ING GET U.S. Core Portfolio - Series 1
ING GET U.S. Core Portfolio - Series 2
ING GET U.S. Opportunity Portfolio - Series 1
ING GET U.S. Opportunity Portfolio - Series 2
ING Global Equity Dividend Fund
ING Global Real Estate Fund
ING GNMA Income Fund
ING Growth + Value Fund
ING Growth Opportunities Fund
ING High Yield Bond Fund
ING High Yield Opportunity Fund
ING Intermediate Bond Fund
ING International Fund
ING International SmallCap Growth Fund
ING International Value Fund
ING LargeCap Growth Fund
ING Lexington Money Market Trust
ING MagnaCap Fund
ING MidCap Opportunities Fund
ING MidCap Value Fund
ING Money Market Fund
ING National Tax-Exempt Bond Fund
ING Precious Metals Fund
ING PRIME RATE TRUST
ING Principal Protection Fund
ING Principal Protection Fund II
ING Principal Protection Fund III
ING Principal Protection Fund IV
ING Principal Protection Fund IX
ING Principal Protection Fund V
ING Principal Protection Fund VI
ING Principal Protection Fund VII
ING Principal Protection Fund VIII
ING Real Estate Fund
ING Research Enhanced Index Fund
ING Russia Fund
ING SENIOR INCOME FUND
ING SmallCap Opportunities Fund
ING SmallCap Value Fund
ING Strategic Bond Fund
ING Tax Efficient Equity Fund
ING VP Convertible Portfolio
ING VP EMERGING MARKETS FUND, INC.
ING VP Financial Services Portfolio
ING VP Growth + Value Portfolio
ING VP Growth Opportunities Portfolio
ING VP High Yield Bond Portfolio
ING VP International Portfolio
ING VP International SmallCap Growth Portfolio
ING VP International Value Portfolio
ING VP LargeCap Growth Portfolio
ING VP MagnaCap Portfolio
ING VP MidCap Opportunities Portfolio
ING VP NATURAL RESOURCES TRUST
ING VP Research Enhanced Index Portfolio
ING VP SmallCap Opportunities Portfolio
ING VP Worldwide Growth Portfolio
ING Worldwide Growth Fund
The Asset Allocation Portfolio
The Bond Portfolio
The Money Market Portfolio
The Stock Portfolio



                               AMENDED SCHEDULE A

                               WITH RESPECT TO THE

                       ALLOCATION AGREEMENT - BLANKET BOND
                              (FEBRUARY 25, 2003)

ING Classic Money Market Fund
ING Convertible Fund
ING Emerging Countries Fund
ING Equity and Bond Fund
ING Financial Services Fund
ING GET U.S. Core Portfolio - Series 1
ING GET U.S. Core Portfolio - Series 2
ING GET U.S. Opportunity Portfolio - Series 1
ING GET U.S. Opportunity Portfolio - Series 2
ING Global Equity Dividend Fund
ING Global Real Estate Fund
ING Global Technology Fund
ING GNMA Income Fund
ING Growth + Value Fund
ING Growth Opportunities Fund
ING High Yield Bond Fund
ING High Yield Opportunity Fund
ING Intermediate Bond Fund
ING International Fund
ING International SmallCap Growth Fund
ING International Value Fund
ING LargeCap Growth Fund
ING Lexington Money Market Trust
ING MagnaCap Fund
ING MidCap Opportunities Fund
ING MidCap Value Fund
ING Money Market Fund
ING National Tax-Exempt Bond Fund
ING Precious Metals Fund
ING PRIME RATE TRUST
ING Principal Protection Fund
ING Principal Protection Fund II
ING Principal Protection Fund III
ING Principal Protection Fund IV
ING Principal Protection Fund IX
ING Principal Protection Fund V
ING Principal Protection Fund VI
ING Principal Protection Fund VII
ING Principal Protection Fund VIII
ING Real Estate Fund
ING Research Enhanced Index Fund
ING Russia Fund
ING SENIOR INCOME FUND
ING SmallCap Opportunities Fund
ING SmallCap Value Fund
ING Strategic Bond Fund
ING Tax Efficient Equity Fund
ING VP Convertible Portfolio
ING VP EMERGING MARKETS FUND, INC.
ING VP Financial Services Portfolio
ING VP Growth + Value Portfolio
ING VP Growth Opportunities Portfolio
ING VP High Yield Bond Portfolio
ING VP International Portfolio
ING VP International SmallCap Growth Portfolio
ING VP International Value Portfolio
ING VP LargeCap Growth Portfolio
ING VP MagnaCap Portfolio
ING VP MidCap Opportunities Portfolio
ING VP NATURAL RESOURCES TRUST
ING VP Research Enhanced Index Portfolio
ING VP SmallCap Opportunities Portfolio
ING VP Worldwide Growth Portfolio
ING Worldwide Growth Fund
The Asset Allocation Portfolio
The Bond Portfolio
The Money Market Portfolio
The Stock Portfolio



                               AMENDED SCHEDULE A

                              WITH RESPECT TO THE

                       ALLOCATION AGREEMENT - BLANKET BOND

Fund For Life Series
ING AIM Mid Cap Growth Portfolio
ING Alliance Mid Cap Growth Portfolio
ING American Funds Growth Portfolio
ING American Funds Growth-Income Portfolio
ING American Funds International Portfolio
ING Capital Guardian Large Cap Value Portfolio
ING Capital Guardian Managed Global Portfolio
ING Capital Guardian Small Cap Portfolio
ING Classic Money Market Fund
ING Convertible Fund
ING Developing World Portfolio
ING Disciplined LargeCap Fund
ING Eagle Asset Value Equity Portfolio
ING Emerging Countries Fund
ING Equity and Bond Fund
ING Financial Services Fund
ING FMR(SM) Diversified Mid Cap Portfolio
ING Foreign Fund
ING GET U.S. Core Portfolio - Series 1
ING GET U.S. Core Portfolio - Series 2
ING GET U.S. Core Portfolio - Series 3
ING GET U.S. Core Portfolio - Series 4
ING GET U.S. Core Portfolio - Series 5
ING GET U.S. Core Portfolio - Series 6
ING GET U.S. Core Select Portfolio - Series 1
ING GET U.S. Core Select Portfolio - Series 2
ING GET U.S. Opportunity Portfolio - Series 1
ING GET U.S. Opportunity Portfolio - Series 2
ING Global Equity Dividend Fund
ING Global Real Estate Fund
ING GNMA Income Fund
ING Goldman Sachs Internet Tollkeeper(SM) Portfolio
ING Growth + Value Fund
ING Growth Opportunities Fund
ING Hard Assets Portfolio
ING High Yield Bond Fund
ING High Yield Opportunity Fund
ING Intermediate Bond Fund
ING International Fund
ING International Portfolio
ING International SmallCap Growth Fund
ING International Value Fund
ING Janus Growth and Income Portfolio
ING Janus Special Equity Portfolio
ING Jennison Equity Opportunities Portfolio
ING JPMorgan Fleming Small Cap Equity Portfolio
ING Julius Baer Foreign Portfolio
ING LargeCap Growth Fund
ING Lexington Money Market Trust
ING Limited Maturity Bond Portfolio
ING Liquid Assets Portfolio
ING MagnaCap Fund
ING Marsico Growth Portfolio
ING Mercury Focus Value Portfolio
ING Mercury Fundamental Growth Portfolio
ING MFS Mid Cap Growth Portfolio
ING MFS Research Portfolio
ING MFS Total Return Portfolio
ING MidCap Opportunities Fund
ING MidCap Value Fund
ING Money Market Fund
ING National Tax-Exempt Bond Fund
ING PIMCO Core Bond Portfolio
ING PIMCO High Yield Portfolio
ING Precious Metals Fund
ING PRIME RATE TRUST
ING Principal Protection Fund
ING Principal Protection Fund II
ING Principal Protection Fund III
ING Principal Protection Fund IV
ING Principal Protection Fund IX
ING Principal Protection Fund V

*  Last updated August 21, 2003.


ING Principal Protection Fund VI
ING Principal Protection Fund VII
ING Principal Protection Fund VIII
ING Real Estate Fund
ING Russia Fund
ING Salomon Brothers All Cap Portfolio
ING Salomon Brothers Investors Portfolio
ING SENIOR INCOME FUND
ING SmallCap Opportunities Fund
ING SmallCap Value Fund
ING Stock Index Portfolio
ING Strategic Bond Fund
ING T. Rowe Price Capital Appreciation Portfolio
ING T. Rowe Price Equity Income Portfolio
ING Tax Efficient Equity Fund
ING UBS U.S. Balanced Portfolio
ING Van Kampen Equity Growth Portfolio
ING Van Kampen Global Franchise Portfolio
ING Van Kampen Growth and Income Portfolio
ING Van Kampen Real Estate Portfolio
ING VP Convertible Portfolio
ING VP Disciplined LargeCap Portfolio
ING VP EMERGING MARKETS FUND, INC.
ING VP Financial Services Portfolio
ING VP Growth + Value Portfolio
ING VP Growth Opportunities Portfolio
ING VP High Yield Bond Portfolio
ING VP International Portfolio
ING VP International SmallCap Growth Portfolio
ING VP International Value Portfolio
ING VP LargeCap Growth Portfolio
ING VP MagnaCap Portfolio
ING VP MidCap Opportunities Portfolio
ING VP NATURAL RESOURCES TRUST
ING VP SmallCap Opportunities Portfolio
ING VP Worldwide Growth Portfolio
ING Worldwide Growth Fund
The Asset Allocation Portfolio
The Bond Portfolio
The Money Market Portfolio
The Stock Portfolio

                                       2


                               AMENDED SCHEDULE A

                               WITH RESPECT TO THE

                       ALLOCATION AGREEMENT - BLANKET BOND

Fund For Life Series(1)
ING AIM Mid Cap Growth Portfolio(1)
ING Alliance Mid Cap Growth Portfolio(1)
ING American Funds Growth Portfolio(1)
ING American Funds Growth-Income Portfolio(1)
ING American Funds International Portfolio(1)
ING Capital Guardian Large Cap Value Portfolio(1)
ING Capital Guardian Managed Global Portfolio(1)
ING Capital Guardian Small Cap Portfolio(1)
ING Classic Money Market Fund
ING Convertible Fund
ING Developing World Portfolio(1)
ING Disciplined LargeCap Fund
ING Eagle Asset Value Equity Portfolio(1)
ING Emerging Countries Fund
ING Equity and Bond Fund
ING Financial Services Fund
ING FMR(SM) Diversified Mid Cap Portfolio(1)
ING Foreign Fund
ING GET U.S. Core Portfolio - Series 1
ING GET U.S. Core Portfolio - Series 2
ING GET U.S. Core Portfolio - Series 3
ING GET U.S. Core Portfolio - Series 4
ING GET U.S. Core Portfolio - Series 5
ING GET U.S. Core Portfolio - Series 6
ING GET U.S. Core Select Portfolio - Series 1
ING GET U..S. Core Select Portfolio - Series 2
ING GET U.S. Opportunity Portfolio - Series 1
ING GET U.S. Opportunity Portfolio- Series 2
ING Global Equity Dividend Fund
ING Global Real Estate Fund
ING GNMA Income Fund
ING Goldman Sachs Internet Tollkeeper(SM) Portfolio(1)
ING Growth + Value Fund
ING Growth Opportunities Fund
ING Hard Assets Portfolio(1)
ING High Yield Bond Fund
ING High Yield Opportunity Fund
ING Intermediate Bond Fund
ING International Fund
ING International Portfolio(1)
ING International SmallCap Growth Fund
ING International Value Fund
ING Janus Growth and Income Portfolio(1)
ING Janus Special Equity Portfolio(1)
ING Jennison Equity Opportunities Portfolio(1)
ING JPMorgan Small Cap Equity Portfolio(1)
ING Julius Baer Foreign Portfolio(1)
ING LargeCap Growth Fund
ING LargeCap Value Fund
ING Lexington Money Market Trust
ING Limited Maturity Bond Portfolio(1)
ING Liquid Assets Portfolio(1)
ING MagnaCap Fund
ING Marsico Growth Portfolio(1)
ING Mercury Focus Value Portfolio(1)
ING Mercury Fundamental Growth Portfolio(1)
ING MFS Mid Cap Growth Portfolio(1)
ING MFS Research Portfolio(1)
ING MFS Total Return Portfolio(1)
ING MidCap Opportunities Fund
ING MidCap Value Fund
ING Money Market Fund
ING National Tax-Exempt Bond Fund
ING PIMCO Core Bond Portfolio(1)
ING PIMCO High Yield Portfolio(1)
ING Precious Metals Fund
ING PRIME RATE TRUST
ING Principal Protection Fund
ING Principal Protection Fund II
ING Principal Protection Fund III

(1)   Under the terms of the Management Agreement between ING Investors Trust
      and Directed Services, Inc., the Fund is subject to a unified fee
      arrangement. Accordingly, the portion of Blanket Bond premium allocated to
      the Fund under the Agreement will be borne directly by Directed Services,
      Inc. as provided in the Management Agreement.

*     Last updated November 11,2003.



ING Principal Protection Fund IV
ING Principal Protection Fund V
ING Principal Protection Fund VI
ING Principal Protection Fund VII
ING Principal Protection Fund VIII
ING Principal Protection Fund IX
ING Real Estate Fund
ING Russia Fund
ING Salomon Brothers All Cap Portfolio(1)
ING Salomon Brothers Investors Portfolio(1)
ING SENIOR INCOME FUND
ING SmallCap Opportunities Fund
ING SmallCap Value Fund
ING Stock Index Portfolio(1)
ING T. Rowe Price Capital Appreciation Portfolio(1)
ING T. Rowe Price Equity Income Portfolio(1)
ING Tax Efficient Equity Fund
ING UBS U.S. Balanced Portfolio(1)
ING Van Kampen Equity Growth Portfolio(1)
ING Van Kampen Global Franchise Portfolio(1)
ING Van Kampen Growth and Income Portfolio(1)
ING Van Kampen Real Estate Portfolio(1)
ING VP Convertible Portfolio
ING VP Disciplined LargeCap Portfolio
ING VP EMERGING MARKETS FUND, INC.
ING VP Financial Services Portfolio
ING VP Growth + Value Portfolio
ING VP Growth Opportunities Portfolio
ING VP High Yield Bond Portfolio
ING VP International Portfolio
ING VP International SmallCap Growth Portfolio
ING VP International Value Portfolio
ING VP LargeCap Growth Portfolio
ING VP MagnaCap Portfolio
ING VP MidCap Opportunities Portfolio
ING VP NATURAL RESOURCES TRUST
ING VP SmallCap Opportunities Portfolio
ING VP Worldwide Growth Portfolio
ING Worldwide Growth Fund
The Asset Allocation Portfolio
The Bond Portfolio
The Money Market Portfolio
The Stock Portfolio

(1)   Under the terms of the Management Agreement between ING Investors Trust
      and Directed Services, Inc., the Fund is subject to a unified fee
      arrangement. Accordingly, the portion of Blanket Bond premium allocated to
      the Fund under the Agreement will be borne directly by Directed Services,
      Inc. as provided in the Management Agreement.

                                       2

                               AMENDED SCHEDULE A

                               WITH RESPECT TO THE

                      ALLOCATION AGREEMENT - BLANKET BOND

FUNDS
 Fund For Life Series(1)
 ING AIM Mid Cap Growth Portfolio(1)
 ING Alliance Mid Cap Growth Portfolio(1)
 ING American Funds Growth Portfolio
 ING American Funds Growth-Income  Portfolio
 ING American Funds International Portfolio
 ING Capital Guardian Large Cap Value  Portfolio(1)
 ING Capital Guardian Managed Global  Portfolio(1)
 ING Capital Guardian Small Cap Portfolio(1)
 ING Classic Money Market Fund
 ING Convertible Fund
 ING Developing World Portfolio(1)
 ING Disciplined LargeCap Fund
 ING Eagle Asset Capital Appreciation Portfolio(1)
 ING Emerging Countries Fund
 ING Equity and Bond Fund
 ING Evergreen Health Sciences Portfolio
 ING Evergreen Omega Portfolio
 ING Financial Services Fund
 ING FMR(SM) Diversified Mid Cap Portfolio(1)
 ING Foreign Fund
 ING GET U.S. Core Portfolio - Series 1
 ING GET U.S. Core Portfolio - Series 2
 ING GET U.S. Core Portfolio - Series 3
 ING GET U.S. Core Portfolio - Series 4
 ING GET U.S. Core Portfolio - Series 5
 ING GET U.S. Core Portfolio - Series 6
 ING GET U.S. Core Select Portfolio - Series 1
 ING GET U.S. Core Select Portfolio - Series 2
 ING GET U.S. Opportunity Portfolio - Series 1
 ING GET U.S. Opportunity Portfolio - Series 2
 ING Global Equity Dividend Fund
 ING Global Real Estate Fund
 ING GNMA Income Fund
 ING Goldman Sachs Internet Tollkeeper(SM)Portfolio(1)
 ING Growth + Value Fund
 ING Growth Opportunities Fund
 ING Hard Assets Portfolio(1)
 ING High Yield Bond Fund
 ING High Yield Opportunity Fund
 ING Intermediate Bond Fund
 ING International Fund
 ING International Portfolio(1)
 ING International SmallCap Growth Fund
 ING International Value Fund
 ING Janus Special Equity Portfolio(1)
 ING Jennison Equity Opportunities Portfolio(1)
 ING JPMorgan Small Cap Equity Portfolio(1)
 ING Julius Baer Foreign Portfolio(1)
 ING LargeCap Growth Fund
 ING LargeCap Value Fund
 ING Legg Mason Value Portfolio(1)
 ING Lexington Money Market Trust
 ING Lifestyle Aggressive Growth Portfolio
 ING Lifestyle Growth Portfolio
 ING Lifestyle Moderate Growth Portfolio
 ING Lifestyle Moderate Portfolio
 ING Limited Maturity Bond Portfolio(1)
 ING Liquid Assets Portfolio(1)
 ING MagnaCap Fund
 ING Marsico Growth Portfolio(1)
 ING Mercury Focus Value Portfolio(1)
 ING Mercury Fundamental Growth Portfolio(1)
 ING MFS Mid Cap Growth Portfolio(1)
 ING MFS Research Portfolio(1)
 ING MFS Total Return Portfolio(1)
 ING MidCap Opportunities Fund
 ING MidCap Value Fund
 ING Money Market Fund
 ING National Tax-Exempt Bond Fund
 ING PIMCO Core Bond Portfolio(1)

(1)  Under the terms of the Management Agreement between ING Investors Trust and
     Directed Services, Inc., the Fund is subject to a unified fee arrangement.
     Accordingly, the portion of Blanket Bond premium allocated to the Fund
     under the Agreement will be borne directly by Directed Services, Inc. as
     provided in the Management Agreement.



ING PIMCO High Yield Portfolio(1)
ING Precious Metals Fund
ING PRIME RATE TRUST
ING Principal Protection Fund
ING Principal Protection Fund II
ING Principal Protection Fund III
ING Principal Protection Fund IV
ING Principal Protection Fund V
ING Principal Protection Fund VI
ING Principal Protection Fund VII
ING Principal Protection Fund VIII
ING Principal Protection Fund IX
ING Principal Protection Fund X
ING Principal Protection Fund XI
ING Real Estate Fund
ING Russia Fund
ING Salomon Brothers All Cap Portfolio(1)
ING Salomon Brothers Investors Portfolio(1)
ING SENIOR INCOME FUND
ING SmallCap Opportunities Fund
ING SmallCap Value Fund
ING Stock Index Portfolio(1)
ING T. Rowe Price Capital Appreciation Portfolio(1)
ING T. Rowe Price Equity Income Portfolio(1)
ING Tax Efficient Equity Fund
ING UBS U.S. Balanced Portfolio(1)
ING Van Kampen Equity Growth Portfolio(1)
ING Van Kampen Global Franchise Portfolio(1)
ING Van Kampen Growth and Income Portfolio(1)
ING Van Kampen Real Estate Portfolio(1)
ING VP Convertible Portfolio
ING VP Disciplined LargeCap Portfolio
ING VP EMERGING MARKETS FUND, INC.
ING VP Financial Services Portfolio
ING VP Growth + Value Portfolio
ING VP Growth Opportunities Portfolio
ING VP High Yield Bond Portfolio
ING VP International Value Portfolio
ING VP LargeCap Growth Portfolio
ING VP MagnaCap Portfolio
ING VP MidCap Opportunities Portfolio
ING VP NATURAL RESOURCES TRUST
ING VP Real Estate Portfolio
ING VP SmallCap Opportunities Portfolio
ING VP Worldwide Growth Portfolio
ING Worldwide Growth Fund
The Asset Allocation Portfolio
The Bond Portfolio
The Money Market Portfolio
The Stock Portfolio

(1)  Under the terms of the Management Agreement between ING Investors Trust and
     Directed Services, Inc., the Fund is subject to a unified fee arrangement.
     Accordingly, the portion of Blanket Bond premium allocated to the Fund
     under the Agreement will be borne directly by Directed Services, Inc. as
     provided in the Management Agreement.

                                       2



                               AMENDED SCHEDULE A

                               WITH RESPECT TO THE

                      ALLOCATION AGREEMENT - BLANKET BOND

FUNDS

 Brokerage Cash Reserves
 Fund For Life Series(1)
 ING Aeltus Money Market Fund
 ING AIM Mid Cap Growth Portfolio(1)
 ING Alliance Mid Cap Growth Portfolio(1)
 ING American Funds Growth Portfolio
 ING American Funds Growth-Income Portfolio
 ING American Funds International Portfolio
 ING Balanced Fund
 ING Bond Fund
 ING Capital Guardian Large Cap Value Portfolio(1)
 ING Capital Guardian Managed Global Portfolio(1)
 ING Capital Guardian Small Cap Portfolio(1)
 ING Classic Money Market Fund
 ING Classic Principal Protection Fund I
 ING Classic Principal Protection Fund II
 ING Classic Principal Protection Fund III
 ING Classic Principal Protection Fund IV
 ING Convertible Fund
 ING Developing World Portfolio(1)
 ING Disciplined LargeCap Fund
 ING Eagle Asset Capital Appreciation Portfolio(1)
 ING Emerging Countries Fund
 ING Equity and Bond Fund
 ING Equity Income Fund
 ING Evergreen Health Sciences Portfolio(1)
 ING Evergreen Omega Portfolio(1)
 ING Financial Services Fund
 ING FMR(SM) Diversified Mid Cap Portfolio(1)
 ING Foreign Fund
 ING GET Fund - Series E
 ING GET Fund - Series G
 ING GET Fund - Series H
 ING GET Fund - Series I
 ING GET Fund - Series J
 ING GET Fund - Series K
 ING GET Fund - Series L
 ING GET Fund - Series M
 ING GET Fund - Series N
 ING GET Fund - Series P
 ING GET Fund - Series Q
 ING GET Fund - Series R
 ING GET Fund - Series S
 ING GET Fund - Series T
 ING GET Fund - Series U
 ING GET Fund - Series V
 ING GET U.S. Core Portfolio - Series 1
 ING GET U.S. Core Portfolio - Series 2
 ING GET U.S. Core Portfolio - Series 3
 ING GET U.S. Core Portfolio - Series 4
 ING GET U.S. Core Portfolio - Series 5
 ING GET U.S. Core Portfolio - Series 6
 ING GET U.S. Core Portfolio - Series 7
 ING GET U.S. Core Portfolio - Series 8
 ING GET U.S. Core Portfolio - Series 9
 ING GET U.S. Core Select Portfolio - Series 1
 ING GET U.S. Core Select Portfolio - Series 2
 ING GET U.S. Opportunity Portfolio - Series 1
 ING GET U.S. Opportunity Portfolio - Series 2
 ING Global Equity Dividend Fund
 ING Global Real Estate Fund
 ING Global Science and Technology Fund
 ING GNMA Income Fund
 ING Goldman Sachs Internet Tollkeeper(SM) Portfolio(1)
 ING Government Fund
 ING Growth Fund
 ING Hard Assets Portfolio(1)
 ING High Yield Bond Fund
 ING High Yield Opportunity Fund
 ING Index Plus LargeCap Fund
 ING Index Plus MidCap Fund
 ING Index Plus Protection Fund
 ING Index Plus SmallCap Fund

(1)  Under the terms of the Management Agreement between ING Investors Trust and
     Directed Services, Inc., the Fund is subject to a unified fee arrangement.
     Accordingly, the portion of Blanket Bond premium allocated to the Fund
     under the Agreement will be borne directly by Directed Services, Inc. as
     provided in the Management Agreement.



ING Intermediate Bond Fund
ING International Fund
ING International Growth Fund
ING International Portfolio(1)
ING International SmallCap Growth Fund
ING International Value Fund
ING Janus Special Equity Portfolio(1)
ING Jennison Equity Opportunities Portfolio(1)
ING JPMorgan Small Cap Equity Portfolio(1)
ING Julius Baer Foreign Portfolio(1)
ING LargeCap Growth Fund
ING LargeCap Value Fund
ING Legg Mason Value Portfolio(1)
ING Lexington Money Market Trust
ING Limited Maturity Bond Portfolio(1)
ING Liquid Assets Portfolio(1)
ING MagnaCap Fund
ING Marsico Growth Portfolio(1)
ING Mercury Focus Value Portfolio(1)
ING Mercury Large Cap Growth Portfolio(1)
ING MFS Mid Cap Growth Portfolio(1)
ING MFS Research Portfolio(1)
ING MFS Total Return Portfolio(1)
ING MidCap Opportunities Fund
ING MidCap Value Fund
ING Money Market Fund
ING National Tax-Exempt Bond Fund
ING PIMCO Core Bond Portfolio(1)
ING PIMCO High Yield Portfolio(1)
ING Precious Metals Fund
ING Prime Rate Trust
ING Principal Protection Fund
ING Principal Protection Fund II
ING Principal Protection Fund III
ING Principal Protection Fund IV
ING Principal Protection Fund IX
ING Principal Protection Fund V
ING Principal Protection Fund VI
ING Principal Protection Fund VII
ING Principal Protection Fund VIII
ING Principal Protection Fund X
ING Principal Protection Fund XI
ING Real Estate Fund
ING Russia Fund
ING Salomon Brothers All Cap Portfolio(1)
ING Salomon Brothers Investors Portfolio(1)
ING Senior Income Fund
ING Small Company Fund
ING SmallCap Opportunities Fund
ING SmallCap Value Fund
ING Stock Index Portfolio(1)
ING Strategic Allocation Balanced Fund
ING Strategic Allocation Growth Fund
ING Strategic Allocation Income Fund
ING T. Rowe Price Capital Appreciation Portfolio(1)
ING T. Rowe Price Equity Income Portfolio(1)
ING Tax Efficient Equity Fund
ING UBS U.S. Balanced Portfolio(1)
ING Value Opportunity Fund
ING Van Kampen Equity Growth Portfolio(1)
ING Van Kampen Global Franchise Portfolio(1)
ING Van Kampen Growth and Income Portfolio(1)
ING Van Kampen Real Estate Portfolio(1)
ING VP Balanced Portfolio, Inc.
ING VP Bond Portfolio
ING VP Convertible Portfolio
ING VP Disciplined LargeCap Portfolio
ING VP Emerging Markets Fund, Inc.
ING VP Financial Services Portfolio
ING VP Global Science and Technology Portfolio
ING VP Growth and Income Portfolio
ING VP Growth Portfolio
ING VP High Yield Bond Portfolio
ING VP Index Plus LargeCap Portfolio
ING VP Index Plus MidCap Portfolio
ING VP Index Plus SmallCap Portfolio
ING VP International Equity Portfolio
ING VP International Value Portfolio
ING VP LargeCap Growth Portfolio
ING VP MagnaCap Portfolio
ING VP MidCap Opportunities Portfolio
ING VP Money Market Portfolio
ING VP Natural Resources Trust
ING VP Real Estate Portfolio
ING VP Small Company Portfolio
ING VP SmallCap Opportunities Portfolio
ING VP Strategic Allocation Balanced Portfolio

(1)  Under the terms of the Management Agreement between ING Investors Trust and
     Directed Services, Inc., the Fund is subject to a unified fee arrangement.
     Accordingly, the portion of Blanket Bond premium allocated to the Fund
     under the Agreement will be borne directly by Directed Services, Inc. as
     provided in the Management Agreement.

                                       2



ING VP Strategic Allocation Growth Portfolio
ING VP Strategic Allocation Income Portfolio
ING VP Value Opportunity Portfolio
ING VP Worldwide Growth Portfolio
ING Worldwide Growth Fund
The Asset Allocation Portfolio
The Bond Portfolio
The Money Market Portfolio
The Stock Portfolio

(1)   Under the terms of the Management Agreement between ING Investors Trust
      and Directed Services, Inc., the Fund is subject to a unified fee
      arrangement. Accordingly, the portion of Blanket Bond premium allocated to
      the Fund under the Agreement will be borne directly by Directed Services,
      Inc. as provided in the Management Agreement.

                                       3



                               AMENDED SCHEDULE A

                               WITH RESPECT TO THE

                      ALLOCATION AGREEMENT - BLANKET BOND

ING INVESTORS TRUST

ING AIM Mid Cap Growth Portfolio(1)
ING Alliance Mid Cap Growth Portfolio(1)
ING American Funds Growth Portfolio
ING American Funds Growth-Income Portfolio
ING American Funds International Portfolio
ING Capital Guardian Large Cap Value Portfolio(1)
ING Capital Guardian Managed Global Portfolio(1)
ING Capital Guardian Small Cap Portfolio(1)
ING Developing World Portfolio(1)
ING Eagle Asset Capital Appreciation Portfolio(1)
ING Evergreen Health Sciences Portfolio(1)
ING Evergreen Omega Portfolio(1)
ING FMR(SM) Diversified Mid Cap Portfolio(1)
ING Goldman Sachs Tollkeeper(SM) Portfolio(1)
ING Hard Assets Portfolio(1)
ING International Portfolio(1)
ING Janus Special Equity Portfolio(1)
ING Jennison Equity Opportunities Portfolio(1)
ING JPMorgan Small Cap Equity Portfolio(1)
ING Julius Baer Foreign Portfolio(1)
ING Legg Mason Value Portfolio(1)
ING Limited Maturity Bond Portfolio(1)
ING Liquid Assets Portfolio(1)
ING Marsico Growth Portfolio(1)
ING Mercury Focus Value Portfolio(1)
ING Mercury Large Cap Growth Portfolio(1)
ING MFS Mid Cap Growth Portfolio(1)
ING MFS Total Return Portfolio(1)
ING Oppenheimer Main Street Portfolio(R)(1)
ING PIMCO Core Bond Portfolio(1)
ING PIMCO High Yield Portfolio(1)
ING Pioneer Fund Portfolio(1)
ING Pioneer Mid Cap Value Portfolio(1)
ING Salomon Brothers All Cap Portfolio(1)
ING Salomon Brothers Investors Portfolio(1)
ING Stock Index Portfolio(1)
ING T. Rowe Price Capital Appreciation Portfolio(1)
ING T. Rowe Price Equity Income Portfolio(1)
ING UBS U.S. Balanced Portfolio(1)
ING Van Kampen Equity Growth Portfolio(1)
ING Van Kampen Global Franchise Portfolio(1)
ING Van Kampen Growth and Income Portfolio(1)
ING Van Kampen Real Estate Portfolio(1)

ING EQUITY TRUST

ING Convertible Fund
ING Disciplined LargeCap Fund
ING Equity and Bond Fund
ING Financial Services Fund
ING LargeCap Value Fund
ING LargeCap Growth Fund
ING MidCap Opportunities Fund
ING MidCap Value Fund
ING Principal Protection Fund
ING Principal Protection Fund II
ING Principal Protection Fund III
ING Principal Protection Fund IV
ING Principal Protection Fund V
ING Principal Protection Fund VI
ING Principal Protection Fund VII
ING Principal Protection Fund VIII
ING Principal Protection Fund IX
ING Principal Protection Fund X
ING Principal Protection Fund XI
ING Principal Protection Fund XII
ING Principal Protection Fund XIII
ING Principal Protection Fund XIV
ING Real Estate Fund
ING SmallCap Opportunities Fund
ING SmallCap Value Fund
ING Tax Efficient Equity Fund

ING FUNDS TRUST

ING Classic Money Market Fund
ING GNMA Income Fund

(1)   Under the terms of the Management Agreement between ING Investors Trust
      and Directed Services, Inc., the Fund is subject to a unified fee
      arrangement. Accordingly, the portion of Blanket Bond premium allocated to
      the Fund under the Agreement will be borne directly by Directed Services,
      Inc. as provided in the Management Agreement.



ING High Yield Bond Fund
ING High Yield Opportunity Fund
ING Intermediate Bond Fund
ING Lexington Money Market Trust
ING Money Market Fund
ING National Tax-Exempt Bond Fund

ING INVESTMENT FUNDS, INC.
ING MagnaCap Fund

ING MAYFLOWER TRUST
ING International Value Fund

ING MUTUAL FUNDS
ING Emerging Countries Fund
ING Foreign Fund
ING Global Equity Dividend Fund
ING Global Real Estate Fund
ING International Fund
ING International SmallCap Growth Fund
ING Precious Metals Fund
ING Russia Fund
ING Worldwide Growth Fund

ING PRIME RATE TRUST

ING SENIOR INCOME FUND

ING VARIABLE INSURANCE TRUST
ING GET U.S. Core Portfolio - Series 1
ING GET U.S. Core Portfolio - Series 2
ING GET U.S. Core Portfolio - Series 3
ING GET U.S. Core Portfolio - Series 4
ING GET U.S. Core Portfolio - Series 5
ING GET U.S. Core Portfolio - Series 6
ING GET U.S. Core Portfolio - Series 7
ING GET U.S. Core Portfolio - Series 8
ING GET U.S. Core Portfolio - Series 9
ING GET U.S. Core Select Portfolio - Series 1
ING GET U.S. Core Select Portfolio - Series 2
ING GET U.S. Opportunity Portfolio - Series 1
ING GET U.S. Opportunity Portfolio - Series 2
ING VP Worldwide Growth Portfolio

ING VARIABLE PRODUCTS TRUST
ING VP Convertible Portfolio
ING VP Disciplined LargeCap Portfolio
ING VP Financial Services Portfolio
ING VP High Yield Bond Portfolio
ING VP International Value Portfolio
ING VP LargeCap Growth Portfolio
ING VP MagnaCap Portfolio
ING VP MidCap Opportunities Portfolio
ING VP Real Estate Portfolio
ING VP SmallCap Opportunities Portfolio

ING VP EMERGING MARKETS FUND, INC.

ING VP NATURAL RESOURCES TRUST

USLICO SERIES FUND
The Asset Allocation Portfolio
The Bond Portfolio
The Money Market Portfolio
The Stock Portfolio

ING GET FUND
ING GET Fund - Series G
ING GET Fund - Series H
ING GET Fund - Series I
ING GET Fund - Series J
ING GET Fund - Series K
ING GET Fund - Series L
ING GET Fund - Series M
ING GET Fund - Series N
ING GET Fund - Series P
ING GET Fund - Series Q
ING GET Fund - Series R
ING GET Fund - Series S
ING GET Fund - Series T
ING GET Fund - Series U
ING GET Fund - Series V

(1)   Under the terms of the Management Agreement between ING Investors Trust
      and Directed Services, Inc., the Fund is subject to a unified fee
      arrangement. Accordingly, the portion of Blanket Bond premium allocated to
      the Fund under the Agreement will be borne directly by Directed Services,
      Inc. as provided in the Management Agreement.

                                       2



ING SERIES FUND, INC.
Brokerage Cash Reserves
ING Aeltus Money Market Fund
ING Balanced Fund
ING Classic Principal Protection Fund II
ING Classic Principal Protection Fund III
ING Classic Principal Protection Fund IV
ING Equity Income Fund
ING Global Science and Technology Fund
ING Government Fund
ING Growth Fund
ING Index Plus LargeCap Fund
ING Index Plus MidCap Fund
ING Index Plus Protection Fund
ING Index Plus SmallCap Fund
ING International Growth Fund
ING Small Company Fund
ING Strategic Allocation Balanced Fund
ING Strategic Allocation Growth Fund
ING Strategic Allocation Income Fund
ING Value Opportunity Fund

ING STRATEGIC ALLOCATION PORTFOLIOS, INC.
ING VP Strategic Allocation Balanced Portfolio
ING VP Strategic Allocation Growth Portfolio
ING VP Strategic Allocation Income Portfolio

ING VARIABLE FUNDS
ING VP Growth and Income Portfolio

ING VARIABLE PORTFOLIOS, INC.
ING VP Global Science and Technology Portfolio
ING VP Growth Portfolio
ING VP Index Plus LargeCap Portfolio
ING VP Index Plus MidCap Portfolio
ING VP Index Plus SmallCap Portfolio
ING VP International Equity Portfolio
ING VP Small Company Portfolio
ING VP Value Opportunity Portfolio

ING VP BALANCED PORTFOLIO, INC.

ING VP INTERMEDIATE BOND PORTFOLIO

ING VP MONEY MARKET PORTFOLIO

(1)   Under the terms of the Management Agreement between ING Investors Trust
      and Directed Services, Inc., the Fund is subject to a unified fee
      arrangement. Accordingly, the portion of Blanket Bond premium allocated to
      the Fund under the Agreement will be borne directly by Directed Services,
      Inc. as provided in the Management Agreement.

                                       3



                               AMENDED SCHEDULE A

                               WITH RESPECT TO THE

                      ALLOCATION AGREEMENT - BLANKET BOND


ING INVESTORS TRUST

ING AIM Mid Cap Growth Portfolio(1)
ING Alliance Mid Cap Growth Portfolio(1)
ING American Funds Growth Portfolio
ING American Funds Growth-Income Portfolio
ING American Funds International Portfolio
ING Capital Guardian Large Cap Value Portfolio(1)
ING Capital Guardian Managed Global Portfolio(1)
ING Capital Guardian Small Cap Portfolio(1)
ING Developing World Portfolio(1)
ING Eagle Asset Capital Appreciation Portfolio(1)
ING Evergreen Health Sciences Portfolio(1)
ING Evergreen Omega Portfolio(1)
ING FMR(SM) Diversified Mid Cap Portfolio(1)
ING FMR(SM) Earnings Growth Portfolio
ING Goldman Sachs Tollkeeper(SM) Portfolio(1)
ING Hard Assets Portfolio(1)
ING International Portfolio(1)
ING Janus Special Equity Portfolio(1)
ING Jennison Equity Opportunities Portfolio(1)
ING JPMorgan Small Cap Equity Portfolio(1)
ING Julius Baer Foreign Portfolio(1)
ING Legg Mason Value Portfolio(1)
ING Limited Maturity Bond Portfolio(1)
ING Liquid Assets Portfolio(1)
ING Marsico Growth Portfolio(1)
ING Marsico International Opportunities Portfolio
ING Mercury Focus Value Portfolio(1)
ING Mercury Large Cap Growth Portfolio(1)
ING MFS Mid Cap Growth Portfolio(1)
ING MFS Total Return Portfolio(1)
ING Oppenheimer Main Street Portfolio(R)(1)
ING PIMCO Core Bond Portfolio(1)
ING PIMCO High Yield Portfolio(1)
ING Pioneer Fund Portfolio(1)
ING Pioneer Mid Cap Value Portfolio(1)
ING Salomon Brothers All Cap Portfolio(1)
ING Salomon Brothers Investors Portfolio(1)
ING Stock Index Portfolio(1)
ING T. Rowe Price Capital Appreciation Portfolio(1)
ING T. Rowe Price Equity Income Portfolio(1)
ING UBS U.S. Balanced Portfolio(1)
ING Van Kampen Equity Growth Portfolio(1)
ING Van Kampen Global Franchise Portfolio(1)
ING Van Kampen Growth and Income Portfolio(1)
ING Van Kampen Real Estate Portfolio(1)

ING EQUITY TRUST

ING Convertible Fund
ING Disciplined LargeCap Fund
ING Equity and Bond Fund
ING Financial Services Fund
ING LargeCap Value Fund
ING LargeCap Growth Fund
ING MidCap Opportunities Fund
ING MidCap Value Fund
ING MidCap Value Choice Fund
ING Principal Protection Fund
ING Principal Protection Fund II
ING Principal Protection Fund III
ING Principal Protection Fund IV
ING Principal Protection Fund V
ING Principal Protection Fund VI
ING Principal Protection Fund VII
ING Principal Protection Fund VIII
ING Principal Protection Fund IX
ING Principal Protection Fund X
ING Principal Protection Fund XI
ING Principal Protection Fund XII
ING Principal Protection Fund XIII
ING Principal Protection Fund XIV
ING Real Estate Fund
ING SmallCap Opportunities Fund
ING SmallCap Value Fund
ING SmallCap Value Choice Fund

(1)   Under the terms of the Management Agreement between ING Investors Trust
      and Directed Services, Inc., the Fund is subject to a unified fee
      arrangement. Accordingly, the portion of Blanket Bond premium allocated to
      the Fund under the Agreement will be borne directly by Directed Services,
      Inc. as provided in the Management Agreement.



ING FUNDS TRUST

ING Classic Money Market Fund
ING GNMA Income Fund
ING High Yield Bond Fund
ING Intermediate Bond Fund
ING Lexington Money Market Trust
ING Money Market Fund
ING National Tax-Exempt Bond Fund

ING INVESTMENT FUNDS, INC.
ING MagnaCap Fund

ING MAYFLOWER TRUST
ING International Value Fund



ING MUTUAL FUNDS

ING Emerging Countries Fund
ING Foreign Fund
ING Global Equity Dividend Fund
ING Global Real Estate Fund
ING Global Value Choice Fund
ING International Fund
ING International SmallCap Growth Fund
ING Precious Metals Fund
ING Russia Fund
ING Worldwide Growth Fund

ING PRIME RATE TRUST


ING SENIOR INCOME FUND

ING VARIABLE INSURANCE TRUST

ING GET U.S. Core Portfolio - Series 1
ING GET U.S. Core Portfolio - Series 2
ING GET U.S. Core Portfolio - Series 3
ING GET U.S. Core Portfolio - Series 4
ING GET U.S. Core Portfolio - Series 5
ING GET U.S. Core Portfolio - Series 6
ING GET U.S. Core Portfolio - Series 7
ING GET U.S. Core Portfolio - Series 8
ING GET U.S. Core Portfolio - Series 9
ING GET U.S. Core Select Portfolio - Series 1
ING GET U.S. Core Select Portfolio - Series 2
ING GET U.S. Opportunity Portfolio - Series 1
ING GET U.S. Opportunity Portfolio - Series 2
ING VP Worldwide Growth Portfolio

ING VARIABLE PRODUCTS TRUST

ING VP Convertible Portfolio
ING VP Disciplined LargeCap Portfolio
ING VP Financial Services Portfolio
ING VP High Yield Bond Portfolio
ING VP International Value Portfolio
ING VP LargeCap Growth Portfolio
ING VP MagnaCap Portfolio
ING VP MidCap Opportunities Portfolio
ING VP Real Estate Portfolio
ING VP SmallCap Opportunities Portfolio

ING VP EMERGING MARKETS FUND, INC.

ING VP NATURAL RESOURCES TRUST

USLICO SERIES FUND

The Asset Allocation Portfolio
The Bond Portfolio
The Money Market Portfolio
The Stock Portfolio

(1)   Under the terms of the Management Agreement between ING Investors Trust
      and Directed Services, Inc., the Fund is subject to a unified fee
      arrangement. Accordingly, the portion of Blanket Bond premium allocated to
      the Fund under the Agreement will be borne directly by Directed Services,
      Inc. as provided in the Management Agreement.

                                       2

                               AMENDED SCHEDULE A

                               WITH RESPECT TO THE

                       ALLOCATION AGREEMENT-BLANKET BOND

ING EQUITY TRUST

ING Convertible Fund
ING Disciplined LargeCap Fund
ING Equity and Bond Fund
ING Financial Services Fund
ING LargeCap Value Fund
ING LargeCap Growth Fund
ING MidCap Opportunities Fund
ING MidCap Value Choice Fund
ING MidCap Value Fund
ING Principal Protection Fund
ING Principal Protection Fund II
ING Principal Protection Fund III
ING Principal Protection Fund IV
ING Principal Protection Fund V
ING Principal Protection Fund VI
ING Principal Protection Fund VII
ING Principal Protection Fund VIII
ING Principal Protection Fund IX
ING Principal Protection Fund X
ING Principal Protection Fund XI
ING Principal Protection Fund XII
ING Principal Protection Fund XIII
ING Principal Protection Fund XIV
ING Real Estate Fund
ING SmallCap Opportunities Fund
ING SmallCap Value Choice Fund
ING SmallCap Value Fund

ING FUNDS TRUST

ING Classic Money Market Fund
ING GNMA Income Fund
ING High Yield Bond Fund
ING High Yield Opportunity Fund
ING Intermediate Bond Fund
ING National Tax-Exempt Bond Fund

ING GLOBAL EQUITY DIVIDEND AND
PREMIUM OPPORTUNITY FUND

ING INVESTORS TRUST

ING AIM Mid Cap Growth Portfolio(1)
ING Alliance Mid Cap Growth Portfolio(1)
ING American Funds Growth Portfolio
ING American Funds Growth-Income Portfolio
ING American Funds International Portfolio
ING Capital Guardian Large Cap Value Portfolio(1)
ING Capital Guardian Managed Global Portfolio(1)
ING Capital Guardian Small/Mid Cap Portfolio(1)
ING Eagle Asset Capital Appreciation Portfolio(1)
ING Evergreen Health Sciences Portfolio(1)
ING Evergreen Omega Portfolio(1)
ING FMR(SM) Diversified Mid Cap Portfolio(1)
ING FMR(SM) Earnings Growth Portfolio
ING Goldman Sachs Tollkeeper(SM) Portfolio(1)
ING Hard Assets Portfolio(1)
ING International Portfolio(1)
ING Janus Contrarian Portfolio(1)
ING Jennison Equity Opportunities Portfolio(1)
ING JPMorgan Emerging Markets Equity Portfolio(1)
ING JPMorgan Small Cap Equity Portfolio(1)
ING JPMorgan Value Opportunities Portfolio
ING Julius Baer Foreign Portfolio(1)
ING Legg Mason Value Portfolio(1)
ING Limited Maturity Bond Portfolio(1)
ING Liquid Assets Portfolio(1)
ING Marsico Growth Portfolio(1)
ING Marsico International Opportunities Portfolio
ING Mercury Focus Value Portfolio(1)
ING Mercury Large Cap Growth Portfolio(1)
ING MFS Mid Cap Growth Portfolio(1)
ING MFS Total Return Portfolio(1)
ING MFS Utilities Portfolio
ING Oppenheimer Main Street Portfolio(R)(1)

(1) Under the terms of the Management Agreement between ING Investors Trust
and Directed Services, Inc., the Fund is subject to a unified fee arrangement.
Accordingly, the portion of SCAS Fees allocated to the Fund under the Agreement
will be borne directly by Directed Services, Inc. as provided in the Management
Agreement.

                                       1


ING PIMCO Core Bond Portfolio(1)
ING PIMCO High Yield Portfolio(1)
ING Pioneer Fund Portfolio(1)
ING Pioneer Mid Cap Value Portfolio(1)
ING Salomon Brothers All Cap Portfolio(1)
ING Salomon Brothers Investors Portfolio(1)
ING Stock Index Portfolio(1)
ING T. Rowe Price Capital Appreciation Portfolio(1)
ING T. Rowe Price Equity Income Portfolio(1)
ING UBS U.S. Balanced Portfolio(1)
ING Van Kampen Equity Growth Portfolio(1)
ING Van Kampen Global Franchise Portfolio(1)
ING Van Kampen Growth and Income Portfolio(1)
ING Van Kampen Real Estate Portfolio(1)

ING INVESTMENT FUNDS, INC.

ING MagnaCap Fund

ING MAYFLOWER TRUST

ING International Value Fund

ING MUTUAL FUNDS

ING Emerging Countries Fund
ING Foreign Fund
ING Global Equity Dividend Fund
ING Global Real Estate Fund
ING Global Value Choice Fund
ING International Fund
ING International SmallCap Fund
ING International Value Choice Fund
ING Precious Metals Fund
ING Russia Fund

ING PARTNERS, INC.

ING American Century Select Portfolio
ING American Century Small Cap Value Portfolio
ING Baron Small Cap Growth Portfolio
ING Fidelity(R) VIP Contrafund(R) Portfolio
ING Fidelity(R) VIP Equity Income Portfolio
ING Fidelity(R) VIP Growth Portfolio
ING Fidelity(R) VIP Mid Cap Portfolio
ING Fundamental Research Portfolio
ING Goldman Sachs(R) Capital Growth Portfolio
ING Goldman Sachs(R) Core Equity Portfolio
ING JPMorgan Fleming International Portfolio
ING JPMorgan Mid Cap Value Portfolio
ING MFS Capital Opportunities Portfolio
ING OpCap Balanced Value Portfolio
ING Oppenheimer Global Portfolio
ING Oppenheimer Strategic Income Portfolio
ING PIMCO Total Return Portfolio
ING Salomon Brothers Aggressive Growth Portfolio
ING Salomon Brothers Fundamental Value Portfolio
ING Salomon Brothers Investors Value Portfolio
ING Salomon Brothers Large Cap Growth Portfolio
ING T. Rowe Price Diversified Mid Cap Growth Portfolio
ING T. Rowe Price Growth Equity Portfolio
ING UBS U.S. Large Cap Equity Portfolio
ING Van Kampen Comstock Portfolio
ING Van Kampen Equity and Income Portfolio

ING PRIME RATE TRUST

ING SENIOR INCOME FUND

ING VARIABLE INSURANCE TRUST

ING GET U.S. Core Portfolio - Series 1
ING GET U.S. Core Portfolio - Series 2
ING GET U.S. Core Portfolio - Series 3
ING GET U.S. Core Portfolio - Series 4
ING GET U.S. Core Portfolio - Series 5
ING GET U.S. Core Portfolio - Series 6
ING GET U.S. Core Portfolio - Series 7
ING GET U.S. Core Portfolio - Series 8
ING GET U.S. Core Portfolio - Series 9
ING GET U.S. Core Select Portfolio - Series 1
ING GET U.S. Core Select Portfolio - Series 2
ING GET U.S. Opportunity Portfolio - Series 1
ING GET U.S. Opportunity Portfolio - Series 2
ING VP Worldwide Growth Portfolio

ING VARIABLE PRODUCTS TRUST

ING VP Convertible Portfolio
ING VP Disciplined LargeCap Portfolio

(1) Under the terms of the Management Agreement between ING Investors Trust
and Directed Services, Inc., the Fund is subject to a unified fee arrangement.
Accordingly, the portion of SCAS Fees allocated to the Fund under the Agreement
will be borne directly by Directed Services, Inc. as provided in the Management
Agreement.

                                       2


ING VP Financial Services Portfolio
ING VP High Yield Bond Portfolio
ING VP International Value Portfolio
ING VP LargeCap Growth Portfolio
ING VP MagnaCap Portfolio
ING VP MidCap Opportunities Portfolio
ING VP Real Estate Portfolio
ING VP SmallCap Opportunities Portfolio
ING VP EMERGING MARKETS FUND, INC.
ING VP NATURAL RESOURCES TRUST

USLICO SERIES FUND

The Asset Allocation Portfolio
The Bond Portfolio
The Money Market Portfolio
The Stock Portfolio

(1) Under the terms of the Management Agreement between ING Investors Trust
and Directed Services, Inc., the Fund is subject to a unified fee arrangement.
Accordingly, the portion of SCAS Fees allocated to the Fund under the Agreement
will be borne directly by Directed Services, Inc. as provided in the
Management Agreement.

                                       3


                               AMENDED SCHEDULE A

                               WITH RESPECT TO THE

                       ALLOCATION AGREEMENT - BLANKET BOND

ING ASIA PACIFIC HIGH DIVIDEND EQUITY
INCOME FUND

ING EQUITY TRUST

ING Financial Services Fund
ING Fundamental Research Fund
ING Index Plus LargeCap Equity Fund
ING Index Plus LargeCap Equity Fund II
ING LargeCap Growth Fund
ING LargeCap Value Fund
ING MidCap Opportunities Fund
ING MidCap Value Fund
ING Principal Protection Fund III
ING Principal Protection Fund IV
ING Principal Protection Fund V
ING Principal Protection Fund VI
ING Principal Protection Fund VII
ING Principal Protection Fund VIII
ING Principal Protection Fund IX
ING Principal Protection Fund X
ING Principal Protection Fund XI
ING Principal Protection Fund XII
ING Real Estate Fund
ING SmallCap Opportunities Fund
ING SmallCap Value Choice Fund
ING SmallCap Value Fund
ING Value Choice Fund

ING FUNDS TRUST

ING Classic Money Market Fund
ING GNMA Income Fund
ING High Yield Bond Fund
ING Institutional Prime Money Market Fund
ING Intermediate Bond Fund
ING National Tax-Exempt Bond Fund

ING GLOBAL ADVANTAGE AND PREMIUM
OPPORTUNITY FUND

ING GLOBAL EQUITY DIVIDEND AND
PREMIUM OPPORTUNITY FUND

ING INVESTMENT FUNDS, INC.

ING MagnaCap Fund

ING INVESTORS TRUST

ING AllianceBernstein Mid Cap Growth Portfolio(1)
ING American Funds Growth Portfolio
ING American Funds Growth-Income Portfolio
ING American Funds International Portfolio
ING BlackRock Inflation Protected Bond Portfolio
ING BlackRock Large Cap Growth Portfolio(1)
ING BlackRock Large Cap Value Portfolio(1)
ING Capital Guardian Small/Mid Cap Portfolio(1)
ING Capital Guardian U.S. Equities Portfolio(1)
ING Disciplined Small Cap Value Portfolio
ING EquitiesPlus Portfolio
ING Evergreen Health Sciences Portfolio(1)
ING Evergreen Omega Portfolio(1)
ING FMR(SM) Diversified Mid Cap Portfolio(1)
ING FMR(SM) Large Cap Growth Portfolio(1)
ING FMR(SM) Mid Cap Growth Portfolio(1)
ING Franklin Income Portfolio(1)
ING Franklin Mutual Shares Portfolio(1)
ING Franklin Templeton Founding Strategy Portfolio
ING Global Real Estate Portfolio
ING Global Resources Portfolio(1)
ING Global Technology Portfolio(1)
ING International Growth Opportunities Portfolio(1)
ING Janus Contrarian Portfolio(1)
ING JPMorgan Emerging Markets Equity Portfolio(1)
ING JPMorgan Small Cap Core Equity Portfolio(1)

(1) Under the terms of the Management Agreement between ING Investors Trust and
Directed Services, LLC, the Fund is subject to a unified fee arrangement.
Accordingly, the portion of SCAS Fees allocated to the Fund under the Agreement
will be borne directly by Directed Services, LLC as provided in the Management
Agreement.

                                       1


ING JPMorgan Value Opportunities Portfolio(1)
ING Julius Baer Foreign Portfolio(1)
ING Legg Mason Value Portfolio(1)
ING LifeStyle Aggressive Growth Portfolio
ING LifeStyle Growth Portfolio
ING LifeStyle Moderate Growth Portfolio
ING LifeStyle Moderate Portfolio
ING Limited Maturity Bond Portfolio(1)
ING Liquid Assets Portfolio(1)
ING Lord Abbett Affiliated Portfolio(1)
ING MarketPro Portfolio
ING MarketStyle Growth Portfolio
ING MarketStyle Moderate Portfolio
ING MarketStyle Moderate Growth Portfolio
ING Marsico Growth Portfolio(1)
ING Marsico International Opportunities Portfolio
ING MFS Total Return Portfolio(1)
ING MFS Utilities Portfolio
ING Oppenheimer Main Street Portfolio(R)(1)
ING PIMCO Core Bond Portfolio(1)
ING PIMCO High Yield Portfolio(1)
ING Pioneer Equity Income Portfolio
ING Pioneer Fund Portfolio(1)
ING Pioneer Mid Cap Value Portfolio(1)
ING Stock Index Portfolio(1)
ING T. Rowe Price Capital Appreciation Portfolio(1)
ING T. Rowe Price Equity Income Portfolio(1)
ING Templeton Global Growth Portfolio(1)
ING UBS U.S. Allocation Portfolio(1)
ING Van Kampen Capital Growth Portfolio(1)
ING Van Kampen Global Franchise Portfolio(1)
ING Van Kampen Growth and Income Portfolio(1)
ING Van Kampen Real Estate Portfolio(1)
ING VP Index Plus International Equity Portfolio
ING Wells Fargo Disciplined Value Portfolio(1)
ING Wells Fargo Small Cap Disciplined Portfolio

ING MAYFLOWER TRUST

ING International Value Fund

ING MUTUAL FUNDS

ING Disciplined International SmallCap Fund
ING Diversified International Fund
ING Emerging Countries Fund
ING Emerging Markets Fixed Income Fund
ING Foreign Fund
ING Global Bond Fund
ING Global Equity Dividend Fund
ING Global Natural Resources Fund
ING Global Real Estate Fund
ING Global Value Choice Fund
ING Greater China Fund
ING Index Plus International Equity Fund
ING International Capital Appreciation Fund
ING International Equity Dividend Fund
ING International Growth Opportunities Fund
ING International Real Estate Fund
ING International SmallCap Fund
ING International Value Choice Fund
ING International Opportunities Fund
ING Russia Fund

ING PARTNERS, INC.

ING American Century Large Company Value Portfolio
ING American Century Small-Mid Cap Value Portfolio

ING Baron Asset Portfolio
ING Baron Small Cap Growth Portfolio
ING Columbia Small Cap Value II Portfolio
ING Davis Venture Value Portfolio
ING Fidelity(R) VIP Contrafund(R) Portfolio
ING Fidelity(R) VIP Equity-Income Portfolio
ING Fidelity(R) VIP Growth Portfolio
ING Fidelity(R) VIP Mid Cap Portfolio
ING Fundamental Research Portfolio
ING JPMorgan International Portfolio
ING JPMorgan Mid Cap Value Portfolio
ING Legg Mason Partners Aggressive Growth Portfolio
ING Legg Mason Partners Large Cap Growth Portfolio
ING Lord Abbett U.S. Government Securities Portfolio
ING Neuberger Berman Partners Portfolio
ING Neuberger Berman Regency Portfolio

(1) Under the terms of the Management Agreement between ING Investors Trust and
Directed Services, LLC, the Fund is subject to a unified fee arrangement.
Accordingly, the portion of SCAS Fees allocated to the Fund under the Agreement
will be borne directly by Directed Services, LLC as provided in the Management
Agreement.

                                       2


ING OpCap Balanced Value Portfolio
ING Oppenheimer Global Portfolio
ING Oppenheimer Strategic Income Portfolio
ING PIMCO Total Return Portfolio
ING Pioneer High Yield Portfolio
ING Solution 2015 Portfolio
ING Solution 2025 Portfolio
ING Solution 2035 Portfolio
ING Solution 2045 Portfolio
ING Solution Income Portfolio
ING T. Rowe Price Diversified Mid Cap Growth
Portfolio
ING T. Rowe Price Growth Equity Portfolio
ING Templeton Foreign Equity Portfolio
ING Thornburg Value Portfolio
ING UBS U.S. Large Cap Equity Portfolio
ING UBS U.S. Small Cap Growth Portfolio
ING Van Kampen Comstock Portfolio
ING Van Kampen Equity and Income Portfolio

ING PRIME RATE TRUST

ING RISK MANAGED NATURAL RESOURCES
FUND

ING SENIOR INCOME FUND

ING SEPARATE PORTFOLIOS TRUST

ING SPorts Core Fixed Income Fund
ING SPorts Core Plus Fixed Income Fund

ING VARIABLE INSURANCE TRUST

ING GET U.S. Core Portfolio - Series 1
ING GET U.S. Core Portfolio - Series 2
ING GET U.S. Core Portfolio - Series 3
ING GET U.S. Core Portfolio - Series 4
ING GET U.S. Core Portfolio - Series 5
ING GET U.S. Core Portfolio - Series 6
ING GET U.S. Core Portfolio - Series 7
ING GET U.S. Core Portfolio - Series 8
ING GET U.S. Core Portfolio - Series 9
ING GET U.S. Core Portfolio - Series 10
ING GET U.S. Core Portfolio - Series 11
ING GET U.S. Core Portfolio - Series 12
ING GET U.S. Core Portfolio - Series 13
ING GET U.S. Core Portfolio - Series 14
ING VP Global Equity Dividend Portfolio

ING VARIABLE PRODUCTS TRUST

ING VP Financial Services Portfolio
ING VP High Yield Bond Portfolio
ING VP International Value Portfolio
ING VP MidCap Opportunities Portfolio
ING VP Real Estate Portfolio
ING VP SmallCap Opportunities Portfolio

(1) Under the terms of the Management Agreement between ING Investors Trust and
Directed Services, LLC, the Fund is subject to a unified fee arrangement.
Accordingly, the portion of SCAS Fees allocated to the Fund under the Agreement
will be borne directly by Directed Services, LLC as provided in the Management
Agreement.

                                       3


40724 Ed.12-90 Printed in U.S.A. INSURED COPY Page 1

DELIVERY INVOICE

Company: ST. PAUL GUARDIAN INSURANCE COMPANY

INSURED

ING FAMILY OF FUNDS
7337 E. DOUBLETREE RANCH RD.
SCOTTSDALE AZ 85258

Policy Inception/Effective Date: 10/01/07
Agency Number: 3142624
Transaction Type:
New Business
Transaction number:
Processing date: 11/05/07
Policy Number: 490PB1692

AGENT

Matt McDonald
Marsh USA
1166 Avenue of the Americas
New York, NY 10036



Policy                                                   Surtax/
Number        Description                Amount         Surcharge
                                               
490PB1692       ICBB                    $13,750


The hard copy of the bond issued by the Underwriter will be referenced in the
event of a loss



40724 Ed.12-90 Printed in U.S.A. INSURED COPY Page 2

The hard copy of the bond issued by the Underwriter will be referenced in the
event of a loss

ND044 Ed. 1-05

2005 The St. Paul Travelers Companies, Inc. All Rights Reserved Page 1 of 1

IMPORTANT NOTICE REGARDING INDEPENDENT AGENT AND BROKER COMPENSATION

Your independent agent or broker may receive a commission from us for placing
your insurance with St. Paul Travelers. Your agent or broker may also receive
additional compensation based on their overall relationship with us or for
writing additional policies with us. As in other industries, this additional
compensation rewards these producers for such things as achieving pre-set
profitability goals, volume levels, growth targets, sales contest objectives or
other measures we may set. Please direct any specific questions about your
insurance representative's compensation to him or her.

The hard copy of the bond issued by the Underwriter will be referenced in the
event of a loss

ND059 Ed. 11-06-1

2006 The St. Paul Travelers Companies, Inc. All Rights Reserved

HOW TO REPORT LOSSES, CLAIMS, OR POTENTIAL CLAIMS TO TRAVELERS

Reporting new losses, claims, or potential claims promptly can be critical. It
helps to resolve covered losses or claims as quickly as possible and often
reduces the overall cost. Prompt reporting: better protects the interests of all
parties; helps Travelers to try to resolve losses or claims more quickly; and
often reduces the overall cost of a loss or claim - losses or claims reported
more than five days after they happen cost on average 35% more than those
reported earlier. Report losses, claims, or potential claims to Travelers easily
and quickly by fax, U S mail, or email.

FAX

Use this number to report a loss, claim, or potential claim by fax toll free.

1-888-460-6622

US MAIL

Use this address to report a loss, claim, or potential claim by US Mail.

Bond-FPS Claims Department
Travelers
Mail Code NB08F
385 Washington Street
Saint Paul, Minnesota 55102

EMAIL

Use this address to report a loss, claim, or potential claim by email.
Pro.E&O.Claim.Reporting@SPT.com

This is a general description of how to report a loss, claim, or potential claim
under this policy or bond. This description does not replace or add to the terms
of this policy or bond. The policy or bond alone determines the scope of
coverage. Please read it carefully for complete information on coverage. Contact
your agent or broker if you have any questions about coverage.

The hard copy of the bond issued by the Underwriter will be referenced in
the event of a loss



XS100 Ed. 5-05
2005 The Travelers Companies, Inc. Page 1 of 5

X ST. PAUL FIRE AND MARINE INSURANCE COMPANY
  ST. PAUL MERCURY INSURANCE COMPANY
  ST. PAUL GUARDIAN INSURANCE COMPANY

A Capital Stock Company

EXCESS FOLLOW FORM

TRAVELERS FORM
DECLARATIONS: Excess Follow Form Number: 490PB1692

The Company designated above (herein called Underwriter) issues this Excess
Follow Form to:

Item 1.

Named Insured:

ING Family of Funds
7337 E. Doubletree Ranch RD
Scottsdale, AZ 85258
(herein called Insured).

Item 2.

Excess Follow Form Period: The Excess Follow Form Period shall be effective at
12:01 A.M. on 10/01/2007 and expire at 12:01 A.M. on 10/01/2008 local time as to
each of said dates, subject to Section 5. of the Terms, Conditions and
Limitations of this Excess Follow Form.

Item 3. Single Loss Limit of Liability: $5,000,000

Item 4. Aggregate Limit of Liability: $5,000,000

Item 5. Schedule of Underlying Insurance:

      (A)   1. Underlying Insurer: Federal Insurance Company

            2. Bond or Policy Number: 81905981

            3. Bond or Policy Period: From: 10/01/2007 To: 10/01/2008

            4. Limit of Liability: Single Loss Limit of Liability $25,000,000
                                   Aggregate Limit of Liability $25,000,000

            5. Single Loss Deductible: $25,000

      (B)   1. Underlying Insurer:

            2. Bond or Policy Number:

            3. Bond or Policy Period:     From:     To:

            4. Limit of Liability: Single Loss Limit of Liability Aggregate
                                   Limit of Liability

      (C)   1. Underlying Insurer:

            2. Bond or Policy Number:

            3. Bond or Policy Period:     From:     To:

            4. Limit of Liability: Single Loss Limit of Liability Aggregate
                                   Limit of Liability

The hard copy of the bond issued by the Underwriter will be referenced in
the event of a loss



XS100 Ed. 5-05
2005 The Travelers Companies, Inc. Page 2 of 5

      (D)   1. Underlying Insurer:

            2. Bond or Policy Number:

            3. Bond or Policy Period:     From:     To:

            4. Limit of Liability: Single Loss Limit of Liability Aggregate
                                   Limit of Liability

Item 6. Total amount of Underlying Single Loss Limit of Liability

The total amount of Underlying Single Loss Limit of Liability is $25,000,000
plus any Single Loss Deductible under the Bond or Policy identified in Item 5.
(A) of the Declarations of this Excess Follow Form.

Item 7. Total amount of Underlying Aggregate Limit of Liability each Excess
Follow Form

Period The total amount of Underlying Aggregate Limit of Liability
each Excess Follow Form Period is $25,000,000 plus any Single Loss Deductible
under the Bond or Policy identified in Item 5. (A) of the Declarations of this
Excess Follow Form.

Item 8. Subject to the Declarations, Insuring Clause, Terms, Conditions and
Limitations and Endorsements of this Excess Follow Form and as excepted below,
this Excess Follow Form follows the form of:

Insurer's Name: Federal Insurance Company
Bond or Policy Number: 81905981
Effective Date: 10/01/2007

Except as provided below:

Item 9. The Insured, by acceptance of this Excess Follow Form, gives notice to
the Underwriter terminating or canceling prior Bond or Policy Numbers NA

such termination or cancellation to be effective as of the time this Excess
Follow Form becomes effective.

Item 10. The liability of the Underwriter is subject to the terms of the
following endorsements attached hereto: NA

/s/ Bruce Backberg
Secretary
/s/ Brian MacLean
President
Executed this 6th day of November 2007 , .Countersigned

The hard copy of the bond issued by the Underwriter will be referenced in the
event of a loss



XS100 Ed. 5-05
2005 The Travelers Companies, Inc. Page 3 of 5

EXCESS FOLLOW FORM

Travelers Form

INSURING CLAUSE

In consideration of the payment of the premium, and in reliance upon
completeness and accuracy of the statements and disclosures made to the
Underwriter and any issuer of Underlying Insurance by application, including all
attachments, subject to the Declarations, Insuring Clause, Terms, Conditions and
Limitations and Endorsements of this Excess Follow Form, this Excess Follow Form
is subject to the same Insuring Clause(s), Terms, Conditions and Limitations and
Endorsements as provided by the Bond or Policy identified in Item 8. of the
Declarations of this Excess Follow Form. In no event shall this Excess Follow
Form provide broader coverage than would be provided by the most restrictive
Underlying Insurance.

This Excess Follow Form is not subject to the same premium or the Limit of
Liability of the Bond or Policy identified in Item 8. of the Declarations.

TERMS, CONDITIONS AND LIMITATIONS

Section 1. Underlying Coverage

A. The Insured(s) shall notify the Underwriter in writing, as soon as
practicable, of a failure to maintain in full force and effect, without
alteration, the coverage and provisions of the Bond(s) or Policy(ies) identified
in Item 5. of the Declarations.

B. In the event there is no recovery available to the Insured as a result of the
insolvency of any Underlying Insurer or the Insured's failure to comply with the
maintenance of any Underlying Insurance, the coverage hereunder shall apply as
excess of the amount of all Underlying Insurance plus the amount of any
applicable deductible to the same extent as if the Underlying Insurance were
maintained in full force and effect.

C. If the coverage and provisions of the Bond or Policy identified in Item 8. of
the Declarations are altered, the Insured shall, as soon as practicable, give
the Underwriter written notice of such alteration(s); and upon receipt of
written consent to such alteration(s) from the Underwriter, the Insured shall
pay any additional premium required by the Underwriter. This Excess Follow Form
shall not follow the form of any alteration(s) to the Bond or Policy identified
in Item 8. of the Declarations unless such written notice thereof is given by
the Insured(s) to the Underwriter, the Underwriter gives written consent to such
alteration(s) and the Insured(s) pay(s) any additional premium required by the
Underwriter.

D. Except as provided in Sections 2.D. and 2.E. below, in no event shall the
Underwriter be liable to pay loss under this Excess Follow Form until the total
amount of the Underlying Single Loss Limit of Liability as stated in Item 6. of
the Declarations has been exhausted solely by reason of the payment of loss by
the Underlying Insurer(s) as covered loss under the applicable Underlying
Insurance.

E. Any claim, loss or coverage that is subject to a Sublimit in any Underlying
Insurance shall not be considered covered loss under this Excess Follow Form,
but shall, for purposes of this Excess Follow Form, reduce or exhaust the
Underlying Limit of Liability to the extent such payment reduces or exhausts the
aggregate limit(s) of liability of such Underlying Insurance.

Section 2. Limit of Liability

A. Payment by the Underwriter of l oss covered under this Excess Follow Form
shall reduce the Aggregate Limit of Liability of this Excess Follow Form set
forth in Item 4. of the Declarations. In the event of exhaustion of the
Aggregate Limit of Liability of this Excess Follow Form set forth in Item 4. of
the Declarations, the Underwriter shall be relieved of all further liability
under this Excess Follow Form.

B. The Underwriter's maximum liability for a Single Loss covered under this
Excess Follow Form shall not exceed the amount of the Single Loss Limit of
Liability stated in Item 3. of the Declarations. Also, the Underwriter's maximum
liability for all loss(es) in the aggregate covered under this Excess Follow
Form shall not exceed the amount of the Aggregate Limit of Liability stated in
Item 4. of the Declarations, which shall be the maximum liability of the
Underwriter in the Excess Follow Form Period stated in Item 2. of the
Declarations.

C. Except as provided in Sections 2.D. and 2.E. below, the Underwriter shall
only be liable to make payment for a Single Loss covered under this Excess
Follow Form after the total amount of the Underlying Single Loss Limit of
Liability as stated in Item 6. of the Declarations has been paid solely by
reason of the payment of loss by the Underlying Insurer(s) as covered loss under
the applicable Underlying Insurance.

The hard copy of the bond issued by the Underwriter will be referenced in the
event of a loss


XS100 Ed. 5-05
2005 The Travelers Companies, Inc. Page 4 of 5

D. In the event the total amount of the Underlying Aggregate Limit of Liability
as stated in Item 7. of the Declarations is reduced solely by reason of the
payment of covered loss by any Underlying Insurer to an amount less than the
total amount of the Underlying Single Loss Limit of Liability as stated in Item
6. of the Declarations, this Excess Follow Form shall pay covered loss excess of
the reduced total amount of Underlying Aggregate Limit of Liability, but not to
exceed the amount of the Single Loss Limit of Liability stated in Item 3. of the
Declarations, and subject always to the remaining Aggregate Limit of Liability
of this Excess Follow Form.

E. In the event of exhaustion of the total amount of Underlying Aggregate Limit
of Liability as set forth in Item 7. of the Declarations, solely by reason of
the payment of covered loss by the Underlying Insurer(s), this Excess Follow
Form shall continue in force as primary insurance, provided always that this
policy shall only pay covered loss excess over any retention or deductible
amount otherwise applicable under the Underlying Insurance scheduled in Item 5.
(A) of the Declarations, such amount not to exceed the Single Loss Limit of
Liability stated in Item 3. of the Declarations and subject always to the
remaining Aggregate Limit of Liability of this Excess Follow Form.

Section 3. Joint Insureds

If two or more Insureds are covered under this Excess Follow Form, the first
named Insured shall act for all Insureds. Payment by the Underwriter to the
first named Insured or to any named Insured of loss covered under this Excess
Follow Form shall fully release the Underwriter on account of such loss. The
liability of the Underwriter for loss(es) sustained by all Insureds shall not
exceed the amount for which the Underwriter would have been liable had all such
loss(es) been sustained by one Insured.

Section 4. Notice / Proof of Loss - Legal Proceedings Against Underwriter

A. The Insured(s) shall, within the time and manner prescribed in the Bond or
Policy identified in Item 8. of the Declarations, give the Underwriter notice of
any loss of the kind covered by this Excess Follow Form, whether or not the
Underwriter is liable therefor in whole or in part, and upon request of the
Underwriter, the Insured(s) shall file with the Underwriter a written statement
of such loss and a copy of all correspondence between the Insured(s) and any
Insurer identified in Item 5. of the Declarations. Notice given to any Insurer
identified in Item 5. of the Declarations of this Excess Follow Form shall not
constitute notice as required under Section 4. of the Terms, Conditions and
Limitations of this Excess Follow Form.

B. The Insured(s) shall, within the time and manner prescribed in the Bond or
Policy identified in Item 8. of the Declarations, file with the Underwriter a
proof of loss for any loss of the kind covered by this Excess Follow Form,
whether or not the Underwriter is liable therefore in whole or in part, and upon
request of the Underwriter the Insured(s) shall furnish a copy of all documents
provided to or made available to any Insurer identified in Item 5. of the
Declarations in support of any proof of loss filed with such Insurer. Filing of
a proof of loss with any Insurer identified in Item 5. of the Declarations shall
not constitute filing a proof of loss with the Underwriter as required in
Section 4. of the Terms, Conditions and Limitations of this Excess Follow Form.

C. Legal proceedings against the Underwriter shall be commenced within the time
prescribed in the Bond or Policy identified in Item 8. of the Declarations and
only after complying with all the Terms, Conditions and Limitations of this
Excess Follow Form.

D. Notice and proof of loss under this Excess Follow Form shall be given to the
Professional E&O Claim Unit, Mail Code 508F, 385 Washington Street, St. Paul, MN
55102.

Section 5. Excess Follow Form Period

A. The term Excess Follow Form Period as used in this Excess Follow Form shall
mean the lesser of the period stated in Item 2. of the Declarations or the time
between the effective date and the termination date of this Excess Follow Form.

B. The Aggregate Limit of Liability set forth in Item. 4. of the Declarations
shall not be cumulated regardless of the number of Excess Follow Form Periods
this Excess Follow Form has been in force; the number of renewals of this Excess
Follow Form by the Underwriter; any extensions of the Excess Follow Form Period
of this Excess Follow Form by the Underwriter; the number of and amount of
premiums paid by the Insured, or the number of Excess Follow Form Periods of
this Excess Follow Form in which the acts giving rise to a loss(es) were
committed or occurred.

The hard copy of the bond issued by the Underwriter will be referenced in the
event of a loss



XS100 Ed. 5-05
2005 The Travelers Companies, Inc. Page 5 of 5

Section 6. Single Loss Defined

As used herein, Single Loss shall be defined as that term, or any similar term,
as defined in the Bond or Policy identified in Item 8. of the Declarations.

Section 7. Cancellation of this Excess Follow Form by the Underwriter or the
Insured

This Excess Follow Form terminates as an entirety upon occurrence of any of the
following: (a) after the receipt by the Insured of a written notice from the
Underwriter of its desire to cancel this Excess Follow Form in accordance with
the conditions and limitations of any Bond or Policy identified in Item 5. of
the Declarations, (b) immediately upon the receipt by the Underwriter of a
written notice from the Insured of its desire to cancel this Excess Follow Form,
or (c) immediately upon cancellation, termination or nonrenewal of the
Underlying Bond or Policy identified in Item 8. of the Declarations, whether by
the Insured or the applicable Underwriter.

In witness whereof, the Underwriter has caused this Excess Follow Form to be
executed on the Declarations page.

The hard copy of the bond issued by the Underwriter will be referenced in
the event of a loss