June 5, 2009
VIA EDGAR
Mr. Jeffrey A. Foor
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: |
| Request for Acceleration of the Effective Date of Registration Statement of ING Variable Funds (on behalf of ING Growth and Income Portfolio) (File No. 333-158794) |
Dear Mr. Foor:
As previously discussed, pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Act”), ING Variable Funds (the “Registrant”) hereby respectfully requests that the effective date of the Registrant’s above referenced registration statement that was filed on Form N-14 with the Securities and Exchange Commission on April 24, 2009, be accelerated so that it will become effective immediately, or as soon thereafter as practicable. The Registrant is aware of its obligations under the Act.
Should you have any questions, please feel free to contact the undersigned at 480.477.2666, or Jutta M. Frankfurter of Dechert LLP at 202.261.3484.
Sincerely,
/s/ Huey P. Falgout |
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Huey P. Falgout, Jr. |
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Chief Counsel |
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ING U.S. Legal Services |
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cc: |
| Christopher C. Okoroegbe, Esq. |
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| ING U.S. Legal Services |
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| Jeffrey S. Puretz, Esq. |
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| Dechert LLP |
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| Jutta M. Frankfurter, Esq. |
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| Dechert LLP |
