Exhibit 11

                                [Form of Opinion]
                                   Dechert LLP
                               1775 I Street, N.W.
                             Washington, D.C. 20006

December 1, 2004

Board of Trustees
ING Funds Trust
7337 E. Doubletree Ranch Road
Scottsdale, AZ 85258-2034

Re:   ING Funds Trust, on behalf of ING Classic Money Market Fund

Dear Ladies and Gentlemen:

We have acted as counsel to ING Funds Trust, a Delaware statutory trust (the
"Trust"), and we have a general familiarity with the Trust's business
operations, practices and procedures. You have asked for our opinion regarding
the issuance of shares of common stock by the Trust in connection with the
acquisition by ING Classic Money Market Fund, a series of the Trust, of the
assets of ING Lexington Money Market Trust ("Lexington Money Market Trust") and
ING Money Market Fund, each a separate series of the Trust, which have been
registered on a Form N-14 Registration Statement (the "Registration Statement")
filed by the Trust with the U.S. Securities and Exchange Commission. We note
that as of the date of this opinion, the Board of Trustees of the Trust has
authorized for issuance unlimited Class A shares, unlimited Class B shares and
unlimited Class C shares of ING Classic Money Market Fund.

We have examined originals or certified copies, or copies otherwise identified
to our satisfaction as being true copies, of various corporate records of the
Trust and such other instruments, documents and records as we have deemed
necessary in order to render this opinion. We have assumed the genuineness of
all signatures, the authenticity of all documents examined by us and the
correctness of all statements of fact contained in those documents.

On the basis of, and subject to, the foregoing, it is our opinion that the
authorized shares of common stock of ING Classic Money Market Fund registered
under the Securities Act of 1933, as amended, in the Registration Statement have
been duly authorized and will be legally and validly issued, fully paid and
non-assessable upon transfer of the assets of Lexington Money Market Trust and
ING Money Market Fund pursuant to the terms of the Agreement and Plan of
Reorganization included in this Registration Statement.

We hereby consent to use of this opinion as an exhibit to the Registration
Statement and to all references to our firm therein.

Very truly yours,
/s/ Dechert