February 20, 2008
VIA EDGAR
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: | ING Variable Products Trust (on behalf of ING VP MidCap Opportunities Portfolio) (File No. 333-148627; CIK# 0000916403) |
| Request for Withdrawal of an Amendment to the Registration Statement Filed on Form N-14 Under EDGAR Form Type “485BPOS” |
Ladies and Gentlemen:
Pursuant to Rule 477 under the Securities Act of 1933, as amended (“1933 Act”), we would like to withdraw a filing for ING Variable Products Trust (the “Trust”). In error, an amendment to the Trust’s registration statement on Form N-14 was submitted on February 19, 2008 under the incorrect EDGAR form type “485BPOS”. The correct EDGAR form type is “N-14/A”. Accordingly, please withdraw the erroneous “485BPOS” filing under accession number 0001104659-08-011556.
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, Jr. |
|
Huey P. Falgout, Jr. |
|
Secretary |
|
cc:
Ms. Alison White
Securities and Exchange Commission
Christopher C. Okoroegbe, Esq.
ING U.S. Legal Services
Jeffrey S. Puretz, Esq.
Jutta M. Frankfurter
Dechert LLP
