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Dechert LLP 1775 I Street, N.W.
Washington, DC 20006-2401
+1 202 261 3300 Main
+1 202 261 3333 Fax
www.dechert.com
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CHRISTOPHER D. CHRISTIAN
christopher.christian@dechert.com
+1 202 261 3321 Direct
+1 202 261 3333 Fax
November 28, 2006
VIA E-MAIL
Mr. Brion Thompson
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: ING Equity Trust - ING Fundamental Research Fund
(File No. 333-137955)
Dear Mr. Thompson:
This letter responds to an additional comment that you provided to me via a
telephone conversation on November 28, 2006, in connection with your review of
Pre-Effective Amendment No. 2 to the Registration Statement filed on Form N-14
on behalf of ING Fundamental Research Fund (the "Acquiring Fund"), a series of
ING Equity Trust (the "Registrant"), on November 22, 2006. The comment, and
the Registrant's response, is as follows:
ACCOUNTING COMMENT
1. COMMENT. Under the section "Introduction," please confirm that the
offering costs of the Acquiring Fund are actually "offering costs," as
defined by Paragraph 8.23 of the Accounting Audit Guide, and are not
organizational costs. If so, the Staff has no further comments on the
disclosure.
RESPONSE. As noted in our response to the Staff dated November 16, 2006,
the offering and organizational expenses included in the gross expense
ratio of the Acquiring Fund are approximately 1.96%. Since this is the
initial year of operation of the Acquiring Fund, such expenses would
naturally be included in the gross expense ratios. As prescribed by
Generally Accepted Accounting Principles (GAAP), organizational expenses
are expensed as incurred while offering expenses are deferred and
amortized over a one-year period. The footnote discloses (i) that these
expenses (1.96% in total) are reflected in the gross expense ratios
because those ratios reflect the first year of operation; and (ii) that
such amount will not recur after December 31, 2006 (the end of the first
year of operation). The 1.96% includes both organizational expenses
which were expensed as incurred as well as
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offering costs which were deferred and are being amortized over a one-year
period ending December 31, 2006. As permissible under Paragraph 8.23 of
the AICPA Audit and Accounting Guide, included in offering costs are
registration fees, costs of printing prospectuses for sales purposes and
legal fees pertaining to shares offered for sale.
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If you have any questions, please do not hesitate to contact Jeffrey S. Puretz
at 202-261-3358 or the undersigned at 202-261-3321.
Sincerely,
/s/ Christopher D. Christian
Christopher D. Christian
cc: Huey Falgout
Paul Caldarelli
ING Investments, LLC
Jeffrey S. Puretz
Dechert LLP