Exhibit 99.11

                           [Letterhead of Dechert LLP]

August 29, 2003


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

Re: ING Variable Products Trust, on behalf of ING VP MagnaCap Portfolio

Dear Ladies and Gentlemen:

We have acted as counsel to ING Variable Products Trust, a Massachusetts
business 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 beneficial interest by the Trust in
connection with the acquisition by ING VP MagnaCap Portfolio, a series of the
Trust, of the assets of ING VP Large Company Value Portfolio, also a 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 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 the foregoing, it is our opinion that the shares of beneficial
interest of the Trust being 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 by the Trust upon
transfer of the assets of ING VP Large Company Value Portfolio 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 LLP