February 15, 2007
VIA EDGAR
Ms. Alison White
Division of Investment Management
United States Securities and Exchange
Commission
100 F Street, NE
Washington, D.C. 20549
Re: | Request for Acceleration of the Effective Date of Registration Statement of ING Variable Products Trust (on behalf of ING VP MidCap Opportunities Portfolio) |
| (File Nos. 333-148627) |
Dear Ms. White:
As previously discussed, pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Act”), ING Variable Products Trust (the “Registrant”) hereby respectfully requests that the effective date of the Registrant’s above-referenced registration statement that was filed with the Securities and Exchange Commission on January 11, 2008, be accelerated so that it will become effective on February 19, 2008, 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 Steven Drachman of Dechert LLP at 212.641.5627.
Sincerely,
/s/ Huey P. Falgout, Jr. |
|
Huey P. Falgout, Jr. |
|
Counsel |
|
ING U.S. Legal Services |
|
cc: | Christopher C. Okoroegbe, Esq. |
| ING U.S. Legal Services |
|
|
|
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| Jeffrey S. Puretz, Esq. |
| Dechert LLP |
