ING


JAMES A. SHUCHART
Counsel


January 3, 2006

U.S. Securities and Exchange Commission
100 F Street, NE
Room 1580
Washington, DC  20549

RE:      ING Life Insurance and Annuity Company
         Registration Statement on Form S-1
         Prospectus Title:  Guaranteed Account
         File No. 333-________

Ladies and Gentlemen:

In my capacity as Counsel of ING Life Insurance and Annuity Company, a
Connecticut domiciled corporation (the "Company"), I have supervised the
preparation of the registration statement for the Guaranteed Account
("Contract") to be filed by the Company with the Securities and Exchange
Commission under the Securities Act of 1933, as amended.

I am of the following opinion:

1.   The Company is a corporation duly organized and validly existing under the
     laws of the State of Connecticut.

2.   The Company is authorized to issue Contracts in those states in which it is
     admitted and upon compliance with applicable local law.

3.   The Contracts, when issued in accordance with the prospectus contained in
     the aforesaid registration statement and upon compliance with applicable
     local law, will be legal and binding obligations of the Company in
     accordance with their terms.

4.   The interests in the Contracts will, when issued and sold in the manner
     described in the registration statement, be legal and binding obligations
     of the Company and will be legally and validly issued, fully paid, and
     non-assessable.

I consent to the filing of this opinion as an exhibit to the Registration
Statement.

Sincerely,

/s/ James A. Shuchart
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James A. Shuchart

1475 Dunwoody Drive                                        Tel:  610-425-3563
West Chester, PA  19380-1478                               Fax:  610-425-3520