EXHIBIT 11

                                   Dechert LLP
                               1775 I Street, N.W.
                             Washington, D.C. 20006

July 29, 2005

Board of Trustees
ING Funds Trust
7337 East Doubletree Ranch Road
Scottsdale, Arizona 85258-2034

Re: ING Funds Trust, on behalf of ING GNMA Income 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 beneficial interest by the Trust in connection with
the acquisition by ING GNMA Income Fund, a series of the Trust, of the assets of
ING Government Fund, a series of ING Series Fund, Inc., 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,
unlimited Class C shares and unlimited Class I shares of ING GNMA Income 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 beneficial interest of ING GNMA Income 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 ING Government 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 LLP