April 24, 2009
VIA EDGAR
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
RE: ING Variable Portfolios, Inc. (on behalf of ING Russell™ Mid Cap Growth Index Portfolio)
Dear Ladies and Gentlemen:
Attached for filing via the EDGAR system is a registration statement on Form N-14 under the Securities Act of 1933, as amended, for ING Variable Portfolios, Inc. (“Registrant”). This Form N-14 is being filed in connection with a reorganization in which ING Russell™ Mid Cap Growth Index Portfolio, a series of the Registrant, will acquire all of the assets of ING AllianceBernstein Mid Cap Growth Portfolio, a series of ING Investors Trust, in exchange for shares of ING Russell™ Mid Cap Growth Index Portfolio and the assumption by ING Russell™ Mid Cap Growth Index Portfolio of the liabilities of ING AllianceBernstein Mid Cap Growth Portfolio, and the approval of a related sub-advisory agreement.
No fees are required in connection with this filing. Should you have any questions please feel free to contact the undersigned at 480-477-2278 or Jutta M. Frankfurter at 202-261-3484.
Very truly yours, | |
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/s/ Chris C. Okoroegbe |
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Christopher C. Okoroegbe | |
Counsel | |
ING U.S. Legal Services | |
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Attachments | |