ThZeal - The Zeal


As filed with the Securities and Exchange		Registration No. 333-
Commission on April 4, 2011
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

FORM S-1
REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933
ING Life Insurance and Annuity Company
Connecticut
71-0294708
One Orange Way, C1S, Windsor, Connecticut 06095-4774, (860) 580-2831

J. Neil McMurdie, Senior Counsel
ING Life Insurance and Annuity Company
One Orange Way, C2N, Windsor, Connecticut 06095-4774
(860) 580-2824

Approximate date of commencement of proposed sale to the public: It is proposed that the
public offering will commence as soon as practicable after effectiveness of this filing.
If any of the securities being registered to this Form are to be offered on a delayed or continuous
basis pursuant to Rule 415 under the Securities Act, check the following box. [ X ]
If this Form is filed to register additional securities for an offering pursuant to Rule 462(b) under
the Securities Act, check the following box and list the Securities Act registration statement
number of the earlier effective registration statement for the same offering. [ X ] 333-158492
If this Form is a post-effective amendment filed pursuant to Rule 462(c) under the Securities Act,
check the following box and list the Securities Act registration statement number of the earlier
effective registration statement for the same offering. [	]
If this Form is a post-effective amendment filed pursuant to Rule 462(d) under the Securities
Act, check the following box and list the Securities Act registration statement number of the
earlier effective registration statement for the same offering. [		]


Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a
non-accelerated filer, or a smaller reporting company. See the definitions of “large accelerated
filer,” “accelerated filer” and “smaller reporting company” in Rule 12b-2 of the Exchange Act.
(Check one):

Large accelerated filer			Accelerated filer

XX Non-accelerated filer			Smaller reporting company


(Do not check if a smaller reporting company)


Calculation of Registration Fee


Title of Each		Proposed	Proposed
Class of		Maximum	Maximum
Securities to be	Amount to be	Offering Price	Aggregate	Amount of
Registered	Registered	Per Unit	Offering Price	Registration Fee

	*	*	$100,000,000	$11,610


*The proposed maximum aggregate offering price is estimated solely for the purpose of
determining the registration fee. The amount to be registered and the proposed maximum
offering price per unit are not applicable since these securities are not issued in predetermined
amounts or units.

Pursuant to Rule 429(b) of the 1933 Act, unsold securities previously registered under
Registration Statement No. 333-158492 are being carried forward to this Registration Statement.
As of February 28, 2011, the amount of such unsold securities was $100,130,000.

The Registrant hereby amends this Registration Statement on such dates as may be
necessary to delay its effective date until the Registrant shall file a further amendment
which specifically states that this Registration Statement shall thereafter become effective
in accordance with Section 8(a) of the Securities Act of 1933 or until the Registration
Statement shall become effective on such date as the Commission, acting pursuant to
Section 8(a), may determine.


ING Life Insurance and Annuity Company

	Guaranteed Accumulation Account Prospectus – April 29, 2011


*Introduction*
The Guaranteed Accumulation Account (GAA) is a fixed interest option available during the accumulation phase of
certain variable annuity contracts issued by ING Life Insurance and Annuity Company (the Company, we, us, our).
Read this prospectus carefully before investing in GAA and save it for future reference.

*General Description*
GAA offers investors the opportunity to earn specified guaranteed rates of interest for specified periods of time,
called guaranteed terms. We generally offer several guaranteed terms at any one time for those considering investing
in GAA. Each guaranteed term offers a guaranteed interest rate for investments that remain in GAA for the duration
of the specific guaranteed term. The guaranteed term establishes both the length of time for which we agree to credit
a guaranteed interest rate and how long your investment must remain in GAA in order to receive the guaranteed
interest rate.

We guarantee both principal and interest if, and only if, your investment remains invested for the full guaranteed
term. Charges related to the contract, such as a maintenance fee or early withdrawal charge, may still apply even if
you do not withdraw until the end of a guaranteed term. Investments taken out of GAA prior to the end of a
guaranteed term may be subject to a market value adjustment, which may result in an investment gain or
loss. See “Market Value Adjustment,” page 12.

This prospectus will explain:
·	Guaranteed interest rates and guaranteed terms;
·	Contributions to GAA;
·	Types of investments available, and how they are classified;
·	How rates are offered;
·	How there can be an investment risk, and how we calculate gain or loss;
·	Contract charges that can affect your account value in GAA;
·	Taking investments out of GAA; and
·	How to reinvest or withdraw at maturity.


*Additional Disclosure Information*
Neither the Securities and Exchange Commission nor any state securities commission has approved or disapproved
of these securities or passed on the accuracy or adequacy of this prospectus. Any representation to the contrary is a
criminal offense. We do not intend for this prospectus to be an offer to sell or a solicitation of an offer to buy these
securities in any state or jurisdiction that does not permit their sale. We have not authorized anyone to provide you
with information that is different than that contained in this prospectus.

Our Home Office:
ING Life Insurance and Annuity Company
One Orange Way
Windsor, Connecticut 06095-4774
1-800-262-3862




PRO.GAA-10


Table of Contents

Summary		3
Description of the Guaranteed Accumulation Account		6
General, Contributions to GAA, Deposit Period, Guaranteed Terms, Guaranteed Term Classifications,
Guaranteed Interest Rates, Interest Rate Lock, Maturity of a Guaranteed Term, Maturity Value Transfer
Provision
Transfers		10
Transfers from GAA, Transfers Between Guaranteed Term Classifications
Withdrawals		11
Deferral of Payments, Reinvestment Privilege
Market Value Adjustment (MVA)		12
Calculation of the MVA, MVA Formula
Contract Charges		15
Other Topics		15
Anti-Money Laundering, The Company, Income Phase, Contract Loans, Investments, Distribution of
Contracts, Taxation, Experts, Legal Matters, Further Information, Incorporation of Certain Documents by
Reference, Inquiries
Appendix I - Examples of Market Value Adjustment Calculations		20
Appendix II - Examples of Market Value Adjustment at Various Yields		24




PRO.GAA-11	2


Summary

GAA is a fixed interest option that may be available during the accumulation			Questions: Contacting the
phase of your annuity contract. The following is a summary of certain facts			Company. To answer your
about GAA.			questions, contact your sales
			representative or write or call
In General. Amounts that you invest in GAA will earn a guaranteed interest			our Home Office at:
rate if left in GAA for a specified period of time (the guaranteed term). You
must invest amounts in GAA for the full guaranteed term in order to receive			ING
the quoted guaranteed interest rate. If you withdraw or transfer those amounts			USFS Customer Service
before the end of the guaranteed term, we may apply a “market value			Defined Contribution
adjustment,” which may be positive or negative.			Administration
			P.O. Box 990063
Deposit Periods. A deposit period is the time during which we offer a			Hartford, CT 06199-0063
specific guaranteed interest rate if you deposit dollars for a specific			1-800-262-3862
guaranteed term. For a particular guaranteed interest rate and guaranteed term
to apply to your account dollars, you must invest them during the deposit
period in which that rate and term are offered.

Guaranteed Terms. A guaranteed term is the period of time account dollars
must be left in GAA in order to earn the guaranteed interest rate specified for
that guaranteed term. We may offer different guaranteed terms at different
times. Check with your representative or the Company to learn the details
about the guaranteed term(s) currently offered. We reserve the right to limit
the number of guaranteed terms or the availability of certain guaranteed terms.
In addition, under certain contracts, we reserve the right to discontinue
offering GAA, or to limit the availability of GAA guaranteed term
classifications.

Some annuity contracts that offer GAA distinguish between short- and long-
term classifications of GAA. Under those contracts, we make the following
distinction:
·	Short-term classification—three years or less; and
·	Long-term classification—between three and ten years.

Guaranteed Interest Rates. We guarantee different interest rates, depending
upon when account dollars are invested in GAA. The interest rate we
guarantee is an annual effective yield; that means that the rate reflects a full
year’s interest. We credit interest at a rate that will provide the guaranteed
annual effective yield over one year. The guaranteed interest rate(s) is
guaranteed for that deposit period and for the length of the guaranteed term.

The guaranteed interest rates we offer will always meet or exceed the
minimum interest rates agreed to in the contract, if any. Not all contracts
provide for minimum interest rates for the GAA. Apart from meeting the
contractual minimum interest rates, if any, we can in no way guarantee any
aspect of future offerings.




PRO.GAA-11		3


Interest Rate Lock. Certain contracts may provide a 45 day interest rate lock in connection with external
transfers into GAA, which you must elect at the time you initiate the external transfer. Under this rate lock
provision, if applicable, we will deposit external transfers to the deposit period offering the greater of (a) and (b)
where:

	a)	Is the guaranteed interest rate for the deposit period in effect at the time we receive the rate lock
		election; and
	b)	Is the guaranteed interest rate for the deposit period in effect at the time we receive an external
		transfer from your prior provider.

If applicable, this rate lock will be available to all external transfers received for 45 days from the date we receive
a rate lock election. In the event we receive an external transfer after this 45 day time period, it will be deposited
to the deposit period in effect at the time we receive the external transfer, and will earn the guaranteed interest rate
for that guaranteed term. Only one rate lock may be in effect at one time per contract – once a rate lock has been
elected, that rate lock will apply to all external transfers received during that 45 day period, and you may not elect
to begin a new rate lock period during that 45 day period.

Amounts subject to the rate lock will not be deposited until the external transfer has been received, and will not be
credited interest until deposited. This could result in the deposit being credited interest for a shorter term than if a
rate lock had not been elected. The cost of providing a rate lock may be a factor we consider when determining
the guaranteed interest rate for a deposit period, which impacts the guaranteed interest rate for all investors in that
guaranteed term.

Fees and Other Deductions. We do not make deductions from amounts in GAA to cover mortality and expense
risks. Rather, we consider these risks when determining the credited rate. The following other types of charges
may be deducted from amounts held in, withdrawn or transferred from GAA:
·	Market Value Adjustment (MVA). An MVA may be applied to amounts transferred or withdrawn prior to the
	end of a guaranteed term, which reflects changes in interest rates since the deposit period. The MVA may be
	positive or negative, and therefore may increase or decrease the amount withdrawn to satisfy a transfer or
	withdrawal request. See “Market Value Adjustment.”
·	Tax Penalties and/or Tax Withholding. Amounts withdrawn may be subject to withholding for federal income
	taxes, as well as a 10% penalty tax for amounts withdrawn prior to your having attained age 59½. See
	“Taxation”; see also the “Tax Considerations” section of the contract prospectus.
·	Early Withdrawal Charge. An early withdrawal charge, which is a deferred sales charge, may apply to
	amounts withdrawn from the contract, in order to reimburse us for some of the sales and administrative
	expenses associated with the contract. See “Contract Charges”; see also the “Fees” section of the contract
	prospectus.
·	Maintenance Fee. An annual maintenance fee of up to $50 may be deducted pro rata from all funding options
	including GAA. See “Contract Charges”; see also the “Fees” section of the contract prospectus.
·	Transfer Fees. Under some contracts transfer fees of up to $10 per transfer may be deducted from amounts
	held in or transferred from GAA during the accumulation phase. See “Contract Charges”; see also the “Fees”
	section of the contract prospectus.
·	Premium Taxes. We may deduct a charge for premium taxes of up to 4% from amounts in GAA. See
	“Contract Charges”; see also the “Fees” section of the contract prospectus.
·	Front End Sales Charges. Under some contracts, we may deduct front end sales charges of up to 6%. See
	“Contract Charges”; see also the “Fees” section of the contract prospectus.

Market Value Adjustment (MVA). If you withdraw or transfer all or part of your account value from GAA
before the guaranteed term is complete, an MVA may apply. The MVA reflects the change in the value of the
investment due to changes in interest rates since the date of deposit. The MVA may be positive or negative
depending upon interest rate activity at the time of withdrawal or transfer.




PRO.GAA-11			4


Any MVA applied to a withdrawal or transfer from GAA will be calculated as an “aggregate MVA,” which is the
sum of all MVAs applicable due to the withdrawal. See the sidebar on page 12 for an example of the calculation
of the aggregate MVA. The following withdrawals will be subject to an aggregate MVA only if it is positive:
· Withdrawals due to the election of a lifetime income option; and
· Withdrawals due to the death of the participant (if paid within the first six months following death). For certain
	contracts issued in the state of New York, this provision also applies in the event of disability, as defined in the
	contract.

All other withdrawals will be subject to an aggregate MVA, regardless of whether it is positive or negative,
including:
·	Withdrawals due to the election of a nonlifetime income option;
·	Payments due to the death of the participant, if paid more than six months following death (or disability, if
	applicable); and
·	Full or partial withdrawals during the accumulation phase (except for withdrawals at the end of a guaranteed
	term or pursuant to the maturity value transfer provision - see “Maturity of a Guaranteed Term” and
	“Maturity Value Transfer Provision”).

Under certain contracts that guarantee a death benefit equal to the greater of the “adjusted purchase total” or the
current account value (excluding loans), the calculation of the current account value will include the aggregate
MVA only if it is positive, regardless of whether the death benefit is paid within six months following death. See
the “Death Benefit” section of the contract prospectus. Under some of these contracts, an election to defer
payment of the death benefit will result in the application of the aggregate MVA, whether positive or negative,
when the beneficiary elects to begin distribution of the death benefit.

See “Description of the Guaranteed Accumulation Account” and “Market Value Adjustment.”

Maturity of a Guaranteed Term. On or before the end of a guaranteed term, the contract holder or you, if
applicable, may instruct us to:
· Transfer the matured amount to one or more new guaranteed terms available under the current deposit period;
· Transfer the matured amount to other available investment options; or
· Withdraw the matured amount.

Amounts withdrawn may be subject to an early withdrawal charge, maintenance fee, tax withholding, and tax
penalties. See “Contract Charges”; see also the “Fees” and “Tax Considerations” sections of the contract
prospectus. When a guaranteed term ends, if we have not received instructions, we will automatically reinvest the
maturing investment into a guaranteed term available in the current deposit period. See “Maturity Value Transfer
Provision.” For contracts that distinguish between short- and long-term classifications, we will generally transfer
the maturing investment to the available deposit period for the guaranteed term having the shortest maturity within
the same classification. For other contracts, we will generally transfer the maturing investment in the following
manner based upon availability:
· To a guaranteed term of the same duration, if available;
· To a guaranteed term with the next shortest duration, if available; or
· To a guaranteed term with the next longest duration.

If you do not provide instructions concerning the maturing amount on or before the end of a guaranteed term, and
this amount is automatically reinvested as noted above, the maturity value transfer provision will apply.

Maturity Value Transfer Provision. If we automatically transfer the matured investment into the current deposit
period, the contract holder or you, if applicable, may, for a limited time, transfer or withdraw all or a portion of
the matured investment that was transferred without the application of an MVA. As described in “Fees and Other
Deductions” above, other fees, including an early withdrawal charge and a maintenance fee, may be assessed on
amounts withdrawn. See “Description of the Guaranteed Accumulation Account.”




PRO.GAA-11		5


Transfer of Account Dollars. Generally, account dollars invested in GAA may be transferred among guaranteed
terms offered through GAA, and/or to other investment options offered through the contract. However:
·	Transfers may not be made during the deposit period in which your account dollars are invested in GAA or
	for 90 days after the close of that deposit period; and
·	We may apply an MVA to transfers made before the end of a guaranteed term.

Transfers to other investment options offered through the contract may be subject to limits on frequent or
disruptive transfers or limits imposed by the underlying funds. See the “Transfers” and “Investment Options”
sections of your contract prospectus.

Investments. Guaranteed interest rates credited during any guaranteed term do not necessarily relate to
investment performance. Deposits received into GAA will generally be invested in federal, state and municipal
obligations, corporate bonds, preferred stocks, real estate mortgages, real estate, certain other fixed income
investments, and cash or cash equivalents. All of our general assets are available to meet guarantees under GAA.

Amounts allocated to GAA are held in a nonunitized separate account established by the Company under
Connecticut law. To the extent provided for in the contract, assets of the separate account are not chargeable with
liabilities arising out of any other business that we conduct. See “Investments.”

Notification of Maturity. We will notify the contract holder or you, if applicable, at least 18 calendar days prior
to the maturity of a guaranteed term. We will include information relating to the current deposit period’s
guaranteed interest rates and the available guaranteed terms. You may obtain information concerning available
deposit periods, guaranteed interest rates, and guaranteed terms by telephone five business days prior to the
maturity date (1-800-GAA-FUND or 1-800-422-3863). See “Description of the Guaranteed Accumulation
Account—General” and “Maturity of a Guaranteed Term.”


Description of the Guaranteed Accumulation Account


*General*

GAA offers guaranteed interest rates for specific guaranteed terms. For a particular guaranteed interest rate and
guaranteed term to apply to your account dollars, you must invest them during the deposit period during which
that rate and term are offered. Each deposit period may offer more than one guaranteed term. Guaranteed terms
may be classified according to length of time to maturity, and each deposit period may offer various guaranteed
terms within these classifications.

Any MVA applied to a withdrawal or transfer from GAA will be calculated as an “aggregate MVA,” which is the
sum of all MVAs applicable due to the withdrawal. See the sidebar on page 12 for an example of the calculation
of the aggregate MVA. The following withdrawals will be subject to an aggregate MVA only if it is positive:
·	Withdrawals due to the election of a lifetime income option; and
·	Withdrawals due to the death of the participant (if paid within the first six months following death). For
	certain contracts issued in the state of New York, this provision also applies in the event of disability, as
	defined in the contract.

All other withdrawals will be subject to an aggregate MVA, regardless of whether it is positive or negative,
including:
·	Withdrawals due to the election of a nonlifetime income option;
·	Payments due to the death of the participant, if paid more than six months following death (or disability, if
	applicable); and
·	Full or partial withdrawals during the accumulation phase (except for withdrawals at the end of a guaranteed
	term or pursuant to the maturity value transfer provision, see “Maturity of a Guaranteed Term” and
	“Maturity Value Transfer Provision”).




PRO.GAA-11		6


We maintain a toll-free telephone number for those wishing to obtain information concerning available deposit
periods, guaranteed interest rates, and guaranteed terms. The telephone number is 1-800-GAA-FUND (1-800-422-
3863). At least 18 calendar days before a guaranteed term matures, we will notify the contract holder or you, if
applicable, of the upcoming deposit period dates and the current guaranteed interest rates, guaranteed terms and
projected matured guaranteed term values.

*Contributions to GAA*

The contract holder or you, if applicable, may invest in the guaranteed terms available in the current deposit
period by allocating new purchase payments to GAA or by transferring a sum from other funding options
available under the contract or from other guaranteed terms.

Though we may require a minimum payment(s) to a contract, we do not require a minimum investment for a
guaranteed term. Refer to the contract prospectus. We reserve the right to establish a minimum amount for
transfers from other funding options.

Investments may not be transferred from a guaranteed term during the deposit period in which the investment is
applied nor during the first 90 days after the close of the deposit period. This restriction does not apply to amounts
transferred or withdrawn under the maturity value transfer provision. See “Maturity Value Transfer Provision.”

*Deposit Period*

The deposit period is the period of time during which the contract holder or you, if applicable, may direct
investments to a particular guaranteed term(s) and receive a stipulated guaranteed interest rate(s). Each deposit
period may be a month, a calendar quarter, or any other period of time we specify.

*Guaranteed Terms*

A guaranteed term is the time we specify during which we credit the guaranteed interest rate. Generally, we will
offer at least one guaranteed term of three years or less and one guaranteed term of more than three years in any
deposit period. However, under certain contracts we reserve the right to limit the guaranteed terms or guaranteed
term classifications offered, as well as the right to discontinue offering GAA. We offer guaranteed terms at our
discretion for various periods ranging from one to ten years.

*Guaranteed Term Classifications*

Some contracts distinguish between long-term and short-term guaranteed term classifications. The following are
the guaranteed term classifications:
·	Short-term—All guaranteed terms of three years or less; and
·	Long-term—All guaranteed terms of between three and ten years.

During each deposit period, we may offer more than one guaranteed term within each guaranteed term
classification. The contract holder or you, if applicable, may allocate investments to guaranteed terms within one
or both guaranteed term classifications during a deposit period.




PRO.GAA-11		7


*Guaranteed Interest Rates*

Guaranteed interest rates are the rates that we guarantee will be credited on amounts applied during a deposit
period for a specific guaranteed term. Guaranteed interest rates are annual effective yields, reflecting a full year’s
interest. We credit interest at a rate that will provide the guaranteed annual effective yield over one year.
Guaranteed interest rates are credited according to the length of the guaranteed term as follows:

Guaranteed Terms of One Year or Less: The guaranteed interest rate is credited from the date of deposit to the
last day of the guaranteed term.

Guaranteed Terms of Greater than One Year: Except for certain contracts issued in the state of New York,
several different guaranteed interest rates may be applicable during a guaranteed term of more than one year. The
initial guaranteed interest rate is credited from the date of deposit to the end of a specified period within the
guaranteed term. We may credit several different guaranteed interest rates for subsequent specific periods of time
within the guaranteed term. For example, for a five-year guaranteed term we may guarantee 5% for the first year,
4.75% for the next two years, and 4.5% for the remaining two years.

We will not guarantee or credit a guaranteed interest rate below the minimum rate specified in the contract for the
GAA, if any. Additionally, we will not credit interest at a rate above the guaranteed interest rate we announce
prior to the start of a deposit period. Not all contracts provide for minimum interest rates for the GAA.
Our guaranteed interest rates are influenced by, but do not necessarily correspond to, interest rates available on
fixed income investments we may buy using deposits directed to GAA. See “Investments.” We consider other
factors when determining guaranteed interest rates including regulatory and tax requirements, sales commissions
and administrative expenses borne by the Company, general economic trends, competitive factors, and whether an
interest rate lock is being offered for that guaranteed term under certain contracts. We make the final
determination regarding guaranteed interest rates. We cannot predict the level of future guaranteed
interest rates.

*Interest Rate Lock*

Certain contracts may provide a 45 day interest rate lock in connection with external transfers into GAA, which
you must elect at the time you initiate the external transfer. Under this rate lock provision, if applicable, we will
deposit external transfers to the deposit period offering the greater of (a) and (b) where:

a)	Is the guaranteed interest rate for the deposit period in effect at the time we receive the rate lock
	election; and
b)	Is the guaranteed interest rate for the deposit period in effect at the time we receive an external
	transfer from your prior provider.

If applicable, this rate lock will be available to all external transfers received for 45 days from the date we receive
a rate lock election. In the event we receive an external transfer after this 45 day time period, it will be deposited
to the deposit period in effect at the time we receive the external transfer, and will earn the guaranteed interest rate
for that guaranteed term. Only one rate lock may be in effect at one time per contract – once a rate lock has been
elected, that rate lock will apply to all external transfers received during that 45 day period, and you may not elect
to begin a new rate lock period during that 45 day period.

Amounts subject to the rate lock will not be deposited until the external transfer has been received, and will not be
credited interest until deposited. This could result in the deposit being credited interest for a shorter term than if a
rate lock had not been elected. The cost of providing a rate lock may be a factor we consider when determining
the guaranteed interest rate for a deposit period, which impacts the guaranteed interest rate for all investors in that
guaranteed term.




PRO.GAA-11		8


*Maturity of a Guaranteed Term*

At least 18 calendar days prior to the maturity of a guaranteed term, we will
notify the contract holder or you, if applicable, of the upcoming deposit
period, the projected value of the amount maturing at the end of the
guaranteed term, and the guaranteed interest rate(s) and guaranteed term(s)
available for the current deposit period.

When a guaranteed term matures, the amounts in any maturing guaranteed
term may be:
·	Transferred to one or more new guaranteed terms available under the
	current deposit period;
·	Transferred to other available investment options; or
·	Withdrawn from the contract.

We do not apply an MVA to amounts transferred or surrendered from a
guaranteed term on the date the guaranteed term matures. Amounts
withdrawn, however, may be subject to an early withdrawal charge, a
maintenance fee, taxation, and tax penalties. If we have not received direction
from the contract holder or you, if applicable, by the maturity date of a
guaranteed term, we will automatically transfer the matured value to one of
the following:

·	For contracts distinguishing between short- and long-term classifications,
	we will generally transfer the amount maturing to the available deposit
	period for the guaranteed term having the shortest maturity within the
	same classification, though it may be different than the maturing term; or
·	For contracts that do not distinguish between short- and long-term
	classifications, we will generally transfer the maturing amount as
	follows:
	> To a guaranteed term of the same duration, if available;
	> To a guaranteed term with the next shortest duration, if available; or
	> To a guaranteed term with the next longest duration.

The contract holder or you, if applicable, will receive a confirmation
statement, plus information on the new guaranteed interest rate(s) and
guaranteed terms.


*Maturity Value Transfer Provision*			*Business Day—*any
			day on which the
If we automatically reinvest the proceeds from a matured guaranteed term,			New York Stock
the contract holder or you, if applicable, may transfer or withdraw from			Exchange is open.
GAA the amount that was reinvested without an MVA. An early withdrawal
charge and maintenance fee may apply to withdrawals. If the full amount
reinvested is transferred or withdrawn, we will include interest credited to
the date of the transfer or withdrawal. This provision is only available until
the last business day of the month following the maturity date of the prior
guaranteed term. This provision only applies to the first transfer or
withdrawal request received from the contract holder or you, if applicable,
with respect to a particular matured guaranteed term value, regardless of the
amount involved in the transaction.




PRO.GAA-11		9


Transfers

We allow the contract holder or you, if applicable, to transfer all or a portion of your account value to GAA or to
other investment options under the contract. We do not allow transfers from any guaranteed term to any other
guaranteed term or investment option during the deposit period for that guaranteed term or for 90 days following
the close of that deposit period, except for amounts transferred under the maturity value transfer provision.

We do not apply an MVA to the value transferred upon maturity of a guaranteed term nor for values transferred
under the maturity value transfer provision. We do not count either of these types of transfers as one of the 12 free
transfers allowed per calendar year by those contracts allowing only 12 free transfers. Transfers to other
investment options through the contract may be subject to limits on frequent or disruptive transfers or limits
imposed by the underlying funds. See the “Transfers” and “Investment Options” sections of your contract
prospectus.

When the contract holder or you, if applicable, requests the transfer of a specific dollar amount, we account for
any applicable MVA in determining the amount to be withdrawn from a guaranteed term(s) to fulfill the request.
Therefore, the amount we actually withdraw from the guaranteed term(s) may be more or less than the requested
dollar amount. See “Appendix I” for an example. For more information on transfers, see the contract prospectus.

*Transfers From GAA*

For contracts that do not distinguish between short- and long-term classifications, the contract holder or you, if
applicable, may choose the guaranteed term from which funds will first be withdrawn. If there is more than one
guaranteed term of the same duration, we will withdraw funds starting from the oldest guaranteed term that has
not reached maturity.

If we do not receive direction, we will withdraw funds pro rata from each guaranteed term in which you are
invested. If there is more than one guaranteed term of the same duration, we will withdraw funds starting from the
oldest guaranteed term that has not reached maturity.

For contracts that distinguish between short- and long-term classifications, the contract holder or you, if
applicable, may choose the guaranteed term classification from which funds will be first withdrawn. We will
withdraw funds starting from the oldest guaranteed term that has not reached maturity within the classification
chosen.

If we do not receive direction, we will withdraw funds pro rata from the guaranteed term classifications, starting
with the oldest guaranteed term that has not reached maturity, and any other investment options.

We will apply an MVA to transfers made before the end of a guaranteed term. See “Market Value Adjustment.”

*Transfers Between Guaranteed Term Classifications*
(For contracts that distinguish between short-term and long-term classifications only)

The contract holder or you, if applicable, may transfer amounts from short-term guaranteed terms to available
long-term guaranteed terms of the current deposit period, or from long-term guaranteed terms to available short-
term guaranteed terms of the current deposit period.

For example, funds may be transferred from a three-year guaranteed term (any time after 90 days from the close
of the deposit period applicable to that three-year guaranteed term) to the open deposit period of a seven-year
guaranteed term.




PRO.GAA-11	10


Funds will be first transferred from the oldest deposit period for which the guaranteed term has not reached
maturity and we will assess an MVA on the transferred amount. These transfers are counted toward the 12 free
transfers allowed per calendar year by those contracts allowing only 12 free transfers.

We do not permit the transfer of value from one guaranteed term prior to its maturity to another guaranteed term
within the same classification. For example, we do not permit transfers from one-year to three-year, one-year to
one-year, five-year to seven-year, or ten-year to seven-year guaranteed terms.


Withdrawals

The contract allows for full or partial withdrawals from GAA at any time during the accumulation phase. To make
a full or partial withdrawal, a request form (available from us) must be properly completed and submitted to our
Home Office (or other designated office as provided in the contract).

Partial withdrawals are made pro rata from funding options unless the contract holder or you, if applicable,
request otherwise. For contracts that do not distinguish between short- and long-term classifications, each
guaranteed term is considered a separate funding option for the purpose of a partial withdrawal.

The contract holder or you, if applicable, may choose the guaranteed term from which funds will be withdrawn. If
there is more than one guaranteed term of the same duration, we will withdraw funds starting from the oldest
guaranteed term that has not reached maturity. If no guaranteed term is elected, we will withdraw funds pro rata
from each guaranteed term in which you are invested.

For contracts distinguishing between short- and long-term classifications, each guaranteed term classification is
considered a separate funding option for the purpose of a partial withdrawal. The contract holder or you, if
applicable, may elect to take a partial withdrawal from either guaranteed term classification. We will first
withdraw funds from the oldest guaranteed term that has not reached maturity within the chosen classification. If
no guaranteed term classification is elected, we will withdraw funds pro rata from each classification (starting
with the oldest guaranteed term that has not reached maturity) and other funding options.

We may apply an MVA to withdrawals made prior to the end of a guaranteed term, except for withdrawals made
under the maturity value transfer provision. See “Market Value Adjustment.” We may deduct an early withdrawal
charge and a maintenance fee depending upon the terms of the contract. The early withdrawal charge is a deferred
sales charge that may be deducted upon withdrawal to reimburse us for some of the sales and administrative
expenses associated with the contract. A maintenance fee up to $50 may be deducted pro rata from each of the
funding options, including GAA. Refer to the contract prospectus for a description of these fees. When a request
for a partial withdrawal of a specific dollar amount is made, we will include the MVA in determining the amount
to be withdrawn from the guaranteed term(s) to fulfill the request. Therefore, the amount we actually take from
the guaranteed term(s) may be more or less than the dollar amount requested. See “Appendix I” for an example.

*Deferral of Payments*

Under certain emergency conditions, we may defer payment of a GAA withdrawal for up to six months. Refer to
the contract prospectus for more details.

*Reinvestment Privilege*

If allowed by the contract, the contract holder or you, if applicable, may elect to reinvest all or a portion of a full
withdrawal during the 30 days following such a withdrawal. We must receive amounts for reinvestment within 60
days of the withdrawal.

We will apply reinvested amounts to the current deposit period. This means that the guaranteed annual interest
rate and guaranteed terms available on the date of reinvestment will apply. Amounts are reinvested in the
guaranteed term classifications, where applicable, in the same proportion as prior to the full withdrawal. Any
negative MVA we applied to a withdrawal will not be refunded, and any taxes that were withheld may also not be
refunded. Refer to the contract prospectus for further details.


PRO.GAA-11	11


	Market Value Adjustment (MVA)

Aggregate MVA is the total of	We apply an MVA to amounts transferred or withdrawn from GAA prior to
all MVAs applied due to a	the end of a guaranteed term. To accommodate early withdrawals or
transfer or withdrawal.	transfers, we may need to liquidate certain assets or use cash that could
	otherwise be invested at current interest rates. When we sell assets
Calculation of the Aggregate	prematurely we could realize a profit or loss depending upon market
MVA—In order to satisfy a	conditions.
transfer or withdrawal,
amounts may be withdrawn	The MVA reflects changes in interest rates since the deposit period. When
from more than one guaranteed	interest rates increase after the deposit period, the value of the investment
term, with more than one	decreases and the market value adjustment amount may be negative.
guaranteed interest rate. In	Conversely, when interest rates decrease after the deposit period, the value of
order to determine the MVA	the investment increases and the market value adjustment amount may be
applicable to such a transfer or	positive. Therefore, the application of an MVA may increase or decrease the
withdrawal, the MVAs	amount withdrawn from a guaranteed term to satisfy a withdrawal or transfer
applicable to each guaranteed	request.
term will be added
together, in order to determine	An MVA applied to a withdrawal or transfer from GAA will be calculated as
the “aggregate MVA.”	an “aggregate MVA,” which is the sum of all MVAs applicable due to the
	withdrawal. See the sidebar on this page for an example of the calculation of
Example: $1,000 withdrawal,	the aggregate MVA. The following withdrawals will be subject to an
two guaranteed terms.	aggregate MVA only if it is positive:
	·	Withdrawals due to the election of a lifetime income option; and
MVA1 = $10, MVA2 = - $30	·	Withdrawals due to the death of the participant (if paid within the first
$10 + - $30 = - $20.		six months following death). For certain contracts issued in the state of
Aggregate MVA = - $20.		New York, this provision also applies in the event of disability, as
		defined in the contract.
Example: $1,000 withdrawal,
two guaranteed terms.	All other withdrawals will be subject to an aggregate MVA, regardless of
	whether it is positive or negative, including:
MVA1 = $30, MVA2 = - $10	·	Withdrawals due to the election of a nonlifetime income option;
$30 + - $10 = $20.	·	Payments due to the death of the participant, if paid more than six
Aggregate MVA = $20.		months following death (or disability, if applicable under your contract);
		and
	·	Full or partial withdrawals during the accumulation phase (except for
		withdrawals at the end of a guaranteed term or pursuant to the maturity
		value transfer provision). See “Maturity of a Guaranteed Term” and
		“Maturity Value Transfer Provision.”

	Should two or more consecutive guaranteed terms have the same guaranteed
	interest rate and mature on the same date, we will calculate an MVA
	applicable to each. We will apply the MVA that is more favorable to you to
	any withdrawal or transfer from either guaranteed term prior to their
	maturity.

	Under some contracts, election of a systematic distribution option, as
	described in the contract prospectus, will not result in an MVA being applied
	to amounts withdrawn from GAA.

	Under certain contracts that guarantee a death benefit equal to the greater of
	the “adjusted purchase total” or the current account value (excluding loans),
	the calculation of the current account value will include the aggregate MVA
	only if it is positive, regardless of whether the death benefit is paid within
	six months following death. See the “Death Benefit” section of the contract
	prospectus. Under some of these contracts, an election to defer payment of
	the death benefit will result in the application of the aggregate MVA,
	whether positive or negative, when the beneficiary elects to begin
	distribution of the death benefit.


PRO.GAA-11		12


Calculation of the MVA

There are two methods for calculating the MVA, and the method that applies to you will be set forth in your contact.
You should check your contract to see which method of calculating the MVA applies to you.

Method One. For contracts that use Method One to calculate the MVA, the amount of the MVA depends on the
relationship between:
· The average corporate bond yield (US Treasury Rate plus spread over Treasury) of the month of deposit for the
corresponding guaranteed term; and
· The current corporate bond yield (US Treasury Rate plus spread over Treasury) at the time of withdrawal for a
period equal to the remainder of the guaranteed term.

If the current corporate bond yield at the time of withdrawal is less than the average corporate bond yield of the
month of deposit, the MVA will decrease the amount withdrawn from a guaranteed term to satisfy a transfer or
withdrawal request (the MVA will be positive). If the current corporate bond yield at the time of withdrawal is
greater than the average corporate bond yield of the month of deposit, the MVA will increase the amount withdrawn
from a guaranteed term (the MVA will be negative).

Method Two. For contracts that do not use Method One to calculate the MVA, the amount of the MVA depends on
the relationship between:
· The deposit period yield of U.S. Treasury Notes that will mature in the last quarter of the guaranteed term; and
· The current yield of such U.S. Treasury Notes at the time of withdrawal.

If the current yield is less than the deposit period yield, the MVA will decrease the amount withdrawn from a
guaranteed term to satisfy a transfer or withdrawal request (the MVA will be positive). If the current yield is greater
than the deposit period yield, the MVA will increase the amount withdrawn from a guaranteed term (the MVA will
be negative).

*Deposit Period Yield*. We determine the deposit period yield used in the MVA calculation by considering
interest rates prevailing during the deposit period of the guaranteed term from which the transfer or withdrawal
will be made. First, we identify the Treasury Notes that mature in the last three months of the guaranteed term.
Then, we determine their yield-to-maturity percentages for the last business day of each week in the deposit
period. We then average the resulting percentages to determine the deposit period yield. Treasury Note
information may be found each business day in publications such as the Wall Street Journal which publishes the
yield-to-maturity percentages for all Treasury Notes as of the preceding business day.

*Current Yield.* We use the same Treasury Notes identified for the deposit period yield to determine the
current yield—Treasury Notes that mature in the last three months of the guaranteed term. However, we use the
yield-to-maturity percentages for the last business day of the week preceding the withdrawal and average those
percentages to get the current yield.




PRO.GAA-11	13


MVA Formulas

Method One. The mathematical formula used to determine the MVA using Method One is:

x
{ ₍₁(1 + + b a + + j) ⁱ⁾} ³⁶⁵


Where:
a is the average of the US Treasury Rate in effect on the first four Fridays of the month of deposit for the
corresponding guaranteed term;
b is the US Treasury Rate in effect on the withdrawal date (based on the previous Friday) for a period equal to the
remainder of the guaranteed term;
i is the average of the spread over Treasury on the Barclays US Corporate Investment Grade Index (if unavailable a
similar service will be utilized) in effect on the first four Fridays of the month of deposit for the corresponding
guaranteed term;
j is the spread over Treasury on the Barclays US Corporate Investment Grade Index (if unavailable a similar service
will be utilized) in effect on the withdrawal date (based on the previous Friday) for a period equal to the remainder
of the guaranteed term; and
x is the number of days remaining, (computed from Wednesday of the week of withdrawal) in the guaranteed term.

Method Two. The mathematical formula used to determine the MVA using Method Two is:

x
{ ₍₁(1 + + j) ⁱ⁾}³⁶⁵


where i is the deposit period yield; j is the current yield; and x is the number of days remaining (computed from
Wednesday of the week of withdrawal) in the guaranteed term.

For examples of how we calculate MVA, refer to Appendix I.

We make an adjustment in the formula of the MVA to reflect the period of time remaining in the guaranteed term
from the Wednesday of the week of a withdrawal.




PRO.GAA-11	14


Contract Charges

Certain charges may be deducted directly or indirectly from the funding options available under the contract,
including GAA.

The contract may have a maintenance fee of up to $50 that we will deduct, on an annual basis, pro rata from all
funding options including GAA. We may also deduct a maintenance fee upon full withdrawal of a contract.

The contract may have an early withdrawal charge that we will deduct, if applicable, upon a full or partial
withdrawal from the contract. If the withdrawal occurs prior to the maturity of a guaranteed term, both the early
withdrawal charge and an MVA may be assessed.

We do not deduct mortality and expense risk charges and other asset-based charges that may apply to variable
funding options from GAA. These charges are only applicable to the variable funding options.

We may deduct a charge for premium taxes of up to 4% from amounts in GAA, and, under some contracts, front
end sales charges of up to 6%.

Under certain contracts, we reserve the right to charge $10 for each transfer of accumulated value between
available investment options over 12.

Refer to the contract prospectus for further details on contract charges.


Other Topics

*Anti-Money Laundering*

In order to protect against the possible misuse of our products in money laundering or terrorist financing, we have
adopted an anti-money laundering program satisfying the requirements of the USA PATRIOT Act and other current
anti-money laundering laws. Among other things, this program requires us, our agents and customers to comply with
certain procedures and standards that will allow us to verify the identity of the sponsoring organization and that
contributions and loan repayments are not derived from improper sources.

Under our anti-money laundering program, we may require customers, and/or beneficiaries to provide sufficient
evidence of identification, and we reserve the right to verify any information provided to us by accessing
information databases maintained internally or by outside firms.

We may also refuse to accept certain forms of payments or loan repayments (traveler’s cheques, cashier's checks,
bank drafts, bank checks and treasurer's checks, for example) or restrict the amount of certain forms of payments or
loan repayments (money orders totaling more than $5,000.00, for example). In addition, we may require information
as to why a particular form of payment was used (third party checks, for example) and the source of the funds of
such payment in order to determine whether or not we will accept it. Use of an unacceptable form of payment may
result in us returning the payment to you.

Applicable laws designed to prevent terrorist financing and money laundering might, in certain
circumstances, require us to block certain transactions until authorization is received from the appropriate
regulator. We may also be required to provide additional information about you and your policy to
government regulators.

Our anti-money laundering program is subject to change without notice to take account of changes in applicable
laws or regulations and our ongoing assessment of our exposure to illegal activity.




PRO.GAA-11	15


*The Company*

ING Life Insurance and Annuity Company (the Company, we, us, our) is a direct, wholly owned subsidiary of
Lion Connecticut Holdings Inc.

We are a stock life insurance company organized under the insurance laws of the State of Connecticut in 1976 and
an indirect wholly owned subsidiary of ING Groep N.V. ("ING"), a global financial institution active in the fields
of insurance, banking and asset management. Through a merger, our operations include the business of Aetna
Variable Annuity Life Insurance Company (formerly known as Participating Annuity Life Insurance Company, an
Arkansas life insurance company organized in 1954). Prior to January 1, 2002, the Company was known as Aetna
Life Insurance and Annuity Company.

Our principal executive offices are located at:
One Orange Way
Windsor, Connecticut 06095-4774
*Income Phase*

GAA may not be used as a funding option during the income phase. Amounts invested in guaranteed terms must
be transferred to one or more of the options available to fund income payments before income payments can
begin.

An aggregate MVA, as previously described, may be applied to amounts transferred to fund income payments
before the end of a guaranteed term. Amounts used to fund lifetime income payments will only receive an
aggregate MVA to the extent it is positive; however amounts transferred to fund a nonlifetime income payment
option may be subject to either a positive or negative aggregate MVA.

Refer to the contract prospectus for a further discussion of the income phase.

*Contract Loans*
(403(b) and some 457 and 401(a) Plans Only)

The contract holder or you, if applicable, may not take a loan from amounts held in GAA, but we include amounts
invested in GAA when calculating the account value that determines the amount available for a loan. Amounts
held in GAA must be transferred to a funding option available for loans in order to be received as a loan. Refer to
the contract prospectus for more information on contract loans. We will apply an MVA to amounts transferred
from guaranteed terms due to a loan request.

*Investments*

Amounts applied to GAA will be deposited in a nonunitized separate account established under Connecticut law.

A nonunitized separate account is a separate account in which neither the contract holder nor you participate in the
performance of the assets through unit values or any other interest. Contract holders and participants allocating
funds to the nonunitized separate account do not receive a unit value of ownership of assets accounted for in this
separate account. The risk of investment gain or loss is borne entirely by the Company. All Company obligations
due to allocations to the nonunitized separate account are contractual guarantees of the Company and are
accounted for in the separate account. All of the general assets of the Company are available to meet our
contractual guarantees. To the extent provided for in the applicable contract, the assets of the nonunitized separate
account are not chargeable with liabilities resulting from any other business of the Company. Income, gains and
losses of the separate account are credited to or charged against the separate account without regard to other
income, gains or losses of the Company.




PRO.GAA-11	16


Types of Investments. We intend to invest primarily in investment-grade fixed income securities including:
·	Securities issued by the United States Government;
·	Issues of U.S. Government agencies or instrumentalities (these issues may or may not be guaranteed by the
	United States Government);
·	Debt securities that have an investment grade, at the time of purchase, within the four highest grades assigned
	by Moody’s Investors Services, Inc. (Aaa, Aa, A or Baa), Standard & Poor’s Corporation (AAA, AA, A or
	BBB) or any other nationally recognized rating service;
·	Other debt instruments, including those issued or guaranteed by banks or bank holding companies, and of
	corporations, which although not rated by Moody’s, Standard & Poor’s, or other nationally recognized rating
	services, are deemed by the Company’s management to have an investment quality comparable to securities
	that may be purchased as stated above; or
·	Commercial paper, cash or cash equivalents, and other short-term investments having a maturity of less than
	one year that are considered by the Company’s management to have investment quality comparable to
	securities, which may be purchased as stated above.

We may invest in futures and options. We purchase financial futures, related options and options on securities
solely for non-speculative hedging purposes. Should securities prices be expected to decline, we may sell a futures
contract or purchase a put option on futures or securities to protect the value of securities held in or to be sold for
the nonunitized separate account. Similarly, if securities prices are expected to rise, we may purchase a futures
contract or a call option against anticipated positive cash flow or may purchase options on securities.

We are not obligated to invest the assets attributable to the contracts according to any particular strategy,
except as required by Connecticut and other state insurance laws. The guaranteed interest rates established
by the Company may not necessarily relate to the performance of the nonunitized separate account.

*Distribution of Contracts*

The Company’s subsidiary, ING Financial Advisers, LLC serves as the principal underwriter for the variable
annuity contracts that include GAA as an investment option. ING Financial Advisers, LLC, a Delaware limited
liability company, is registered as a broker-dealer with the Securities and Exchange Commission. ING Financial
Advisers, LLC is also a member of the Financial Industry Regulatory Authority (FINRA) and the Securities
Investor Protection Corporation. ING Financial Advisers, LLC’s principal office is located at One Orange Way,
Windsor, Connecticut 06095-4774.

As principal underwriter, ING Financial Advisers, LLC may enter into arrangements with one or more registered
broker-dealers to offer and sell the contracts. We and our affiliate(s) may also sell the contracts directly. All
individuals offering and selling the contracts must be registered representatives of a broker-dealer and must be
licensed as insurance agents to sell variable annuity contracts. For additional information, see the contract
prospectus.

*Taxation*

You should seek advice from your tax adviser as to the application of federal (and where applicable, state and
local) tax laws to amounts paid to or distributed under the contracts. Refer to the applicable contract prospectus
for a further discussion of tax considerations.

Taxation of the Company. We are taxed as a life insurance company under Part I of Subchapter L of the Internal
Revenue Code. The Company owns all assets supporting the contract obligations of GAA. Any income earned on
such assets is considered income to the Company. We do not intend to make any provision or impose a charge
under the contracts with respect to any tax liability of the Company.

Taxation of Payments and Distributions. For information concerning the tax treatment of payments to and
distributions from the contracts, please refer to the applicable contract prospectus.




PRO.GAA-11		17


*Experts*

The consolidated financial statements of the Company appearing in the Company’s Annual Report on Form 10-K
for the year ended December 31, 2010 (including schedules appearing therein), have been audited by Ernst & Young
LLP, independent registered public accounting firm, as stated in their reports, which are incorporated by reference,
and incorporated in reliance upon the reports of such firm given upon their authority as experts in accounting and
auditing.

*Legal Matters*

For information regarding legal matters affecting the Company or the distributor of the variable annuity contracts,
please refer to the applicable contract prospectus.

*Further Information*

This prospectus does not contain all of the information contained in the registration statement of which this
prospectus is a part. Portions of the registration statement have been omitted from this prospectus as allowed by the
Securities and Exchange Commission (SEC). You may obtain the omitted information from the offices of the SEC,
as described below.

We are required by the Securities Exchange Act of 1934 to file periodic reports and other information with the SEC.
You may inspect or copy information concerning the Company at the Public Reference Branch of the SEC at:

SEC Public Reference Branch
100 F Street, NE, Room 1580
Washington, D.C. 20549

You may also obtain copies of these materials at prescribed rates from the Public Reference Branch of the above
office. You may obtain information on the operation of the Public Reference Branch by calling the SEC at either 1-
800-SEC-0330 or 1-202-551-8090 or by e-mailing publicinfo@sec.gov. You may also find more information about
the Company by visiting the Company’s homepage on the internet at www.ingretirementplans.com.

Our filings are available to the public on the SEC’s website at www.sec.gov. We also make our filings available on
our website at www.ing-usa.com/us/aboutING/inginsuraneusfinancialreports. (These uniform resource locators
(URLs) are inactive textual references only and are not intended to incorporate the SEC website or our website into
this prospectus.) When looking for more information about the contract, you may find it useful to use the number
assigned to the registration statement under the Securities Act of 1933. This number is 333-158492.

You can also find this prospectus and other information the Company files electronically with the SEC on the SEC’s
web site at http://www.sec.gov.

*Incorporation of Certain Documents by Reference*


The SEC allows us to “incorporate by reference” information that we file with the SEC into this prospectus, which
means that incorporated documents are considered part of this prospectus. We can disclose important information
to you by referring you to those documents. This prospectus incorporates by reference the Annual Report on
Form 10-K for the year ended December 31, 2010. Form 10-K contains additional information about the Company
and includes certified financial statements as of December 31, 2010 and 2009, and for each of the three years in the
period ended December 31, 2010. We were not required to file any other reports pursuant to Sections 13(a) or 15(d)
of the Securities and Exchange Act since December 31, 2010.




PRO.GAA-11	18


				Appendix I

			Examples of Market Value Adjustment Calculations

The following are examples of market value adjustment ("MVA") calculations using several hypothetical
yields, applicable to contracts that use Method One to calculate the MVA. These examples do not include the
effect of any early withdrawal charge or other fees that may be assessed under the contract upon withdrawal.

EXAMPLE I
a is the average of the US Treasury Rate in effect on the first four Fridays of the month of deposit for the
corresponding guaranteed term;
b is the US Treasury Rate in effect on the withdrawal date (based on the previous Friday) for a period equal to the
remainder of the guaranteed term;
i is the average of the spread over Treasury on the Barclays US Corporate Investment Grade Index (if unavailable a
similar service will be utilized) in effect on the first four Fridays of the month of deposit for the corresponding
guaranteed term;
j is the spread over Treasury on the Barclays US Corporate Investment Grade Index (if unavailable a similar service
will be utilized) in effect on the withdrawal date (based on the previous Friday) for a period equal to the remainder
of the guaranteed term; and
x is the number of days remaining, (computed from Wednesday of the week of withdrawal) in the guaranteed term.

Assumptions:					Assumptions:

a	= 3%				a	= 4%
i	= 1%				i	= 1%
b	= 5%				b	= 5%
j	= 1%				j	= 1%
x	= 927				x	= 927

				x			x
MVA		=	{ ₍₁(1 + + b a + + j) ⁱ⁾} ³⁶⁵		MVA =		{ ₍₁(1 + + b a + + j) ⁱ⁾} ³⁶⁵



				927			927
			{ ^(1.04⁾	} ³⁶⁵			{ ^(1.05⁾} ³⁶⁵
MVA		=	(1.06)		MVA =		(1.06)

		= .9528				= .9762


In this example, the average corporate bond yield of the					In this example, the average corporate bond yield
month of deposit (a + i) of 4% is less than the current					of the month of deposit (a + i) of 5% is less than
corporate bond yield at the time of withdrawal (b + j) of					the current corporate bond yield at the time of
6%; therefore, the MVA is less than one. The amount					withdrawal (b + j) of 6%; therefore, the MVA is
withdrawn from the guaranteed term is multiplied by					less than one. The amount withdrawn from the
this MVA.					guaranteed term is multiplied by this MVA.

If a withdrawal or transfer request of a specific dollar					If a withdrawal or transfer request of a specific
amount is requested, the amount withdrawn from a					dollar amount is requested, the amount
guaranteed term will be increased to compensate for the					withdrawn		from a guaranteed term will be
negative MVA amount. For example, a withdrawal					increased to compensate for the negative MVA
request to receive a check for $2,000 would result in a					amount. For example, a withdrawal request to
$2,099.08 withdrawal from the guaranteed term.					receive a check for $2,000 would result in a
					$2,048.76 withdrawal from the guaranteed term.


PRO.GAA-11				20


EXAMPLE II
a is the average of the US Treasury Rate in effect on the first four Fridays of the month of deposit for the
corresponding guaranteed term;
b is the US Treasury Rate in effect on the withdrawal date (based on the previous Friday) for a period equal to the
remainder of the guaranteed term;
i is the average of the spread over Treasury on the Barclays US Corporate Investment Grade Index (if unavailable a
similar service will be utilized) in effect on the first four Fridays of the month of deposit for the corresponding
guaranteed term;
j is the spread over Treasury on the Barclays US Corporate Investment Grade Index (if unavailable a similar service
will be utilized) in effect on the withdrawal date (based on the previous Friday) for a period equal to the remainder
of the guaranteed term; and
x is the number of days remaining, (computed from Wednesday of the week of withdrawal) in the guaranteed term.

Assumptions:					Assumptions:

a	= 5%				a	= 4%
i	= 1%				i	= 1%
b	= 3%				b	= 3%
j	= 1%				j	= 1%
x	= 927				x	= 927

				x					x
MVA		=	{ ₍₁(1 + + b a + + j) ⁱ⁾}³⁶⁵		MVA =		{ (1 (1 + + b a + + j) ⁱ⁾}³⁶⁵



				927					927
			{ ^(1.06⁾	}³⁶⁵			{	^(1.05⁾	}³⁶⁵
MVA		=	(1.04)		MVA =			(1.04)

		= 1.0496				= 1.0246

In this example, the average corporate bond yield of the					In this example, the average corporate bond yield
month of deposit (a + i) of 6% is greater than the current					of the month of deposit (a + i) of 5% is greater
corporate bond yield at the time of withdrawal (b + j) of					than the current corporate bond yield at the time
4%; therefore, the MVA is greater than one. The amount					of withdrawal (b + j) of 4%; therefore, the MVA
withdrawn from the guaranteed term is multiplied by					is greater than one. The amount withdrawn from
this MVA.					the guaranteed term is multiplied by this MVA.

If a withdrawal or transfer request of a specific dollar					If a withdrawal or transfer request of a specific
amount is requested, the amount withdrawn from a					dollar amount is requested, the amount
guaranteed term will be decreased to reflect the positive					withdrawn from a			guaranteed term will be
MVA amount. For example, a withdrawal request to					decreased to reflect the positive MVA amount.
receive a check for $2,000 would result in a $1,905.49					For example, a withdrawal request to receive a
withdrawal from the guaranteed term.					check for $2,000 would result in a $1,951.98
					withdrawal from the guaranteed term.




PRO.GAA-11				21


The following are examples of market value adjustment ("MVA") calculations using several hypothetical
deposit period yields and current yields, applicable to contracts that use Method Two to calculate the MVA.
These examples do not include the effect of any early withdrawal charge or other fees that may be assessed under
the contract upon withdrawal.
EXAMPLE I
Assumptions:				Assumptions:

i,	the deposit period yield, is 4%			i,	the deposit period yield, is 5%
j,	the current yield, is 6%			j,	the current yield, is 6%
x,	the number of days remaining (computed from			x,	the number of days remaining (computed from
	Wednesday of the week of withdrawal) in the				Wednesday of the week of withdrawal) in the
	guaranteed term, is 927.				guaranteed term, is 927.

			x				x
			365				365
			(1 + i)				(1 + i)
MVA		⁼	{ ⁽¹+ ^j⁾}	MVA		⁼	{ ⁽¹+ ^j⁾}


			927				927
			365				365
			(1.04)				(1.05)
MVA		⁼	{ ^(1.06⁾}	MVA		⁼	{ ^(1.06⁾}


		= .9528				= .9762

In this example, the deposit period yield of 4% is less				In this example, the deposit period yield of 5% is
than the current yield of 6%; therefore, the MVA is less				less than the current yield of 6%; therefore, the
than one. The amount withdrawn from the guaranteed				MVA is less than one. The amount withdrawn
term is multiplied by this MVA.				from the guaranteed term is multiplied by this
				MVA.
If a withdrawal or transfer request of a specific dollar
amount		is requested, the amount withdrawn from a		If a withdrawal or transfer request of a specific
guaranteed term will be increased to compensate for the				dollar		amount is requested, the amount
negative MVA amount. For example, a withdrawal				withdrawn from a guaranteed term will be
request to receive a check for $2,000 would result in a				increased to compensate for the negative MVA
$2,099.08 withdrawal from the guaranteed term.				amount. For example, a withdrawal request to
				receive a check for $2,000 would result in a
				$2,048.76 withdrawal from the guaranteed term.




PRO.GAA-11			22


EXAMPLE II

Assumptions:					Assumptions:

i,	the deposit period yield, is 6%				i,	the deposit period yield, is 5%
j,	the current yield, is 4%				j,	the current yield, is 4%
x,	the number of days remaining (computed from				x,	the number of days remaining (computed from
	Wednesday of the week of withdrawal) in the					Wednesday of the week of withdrawal) in the
	guaranteed term, is 927.					guaranteed term, is 927.


			x						x
			365						365
			(1 + i)					(1 + i)
MVA		⁼	{⁽¹+ ^j⁾}		MVA		⁼	{ ⁽¹+ ^j⁾}


			927						927
			365						365
			(1.06)					(1.05)
MVA		⁼	{ ^(1.04⁾}		MVA		⁼	{ ^(1.04⁾}
		= 1.0496					= 1.0246

In this example, the deposit period yield of 6% is					In this example, the deposit period yield of 5% is
greater than the current yield of 4%; therefore, the					greater than the current yield of 4%; therefore,
MVA is greater than one. The amount withdrawn from					the	MVA		is greater	than one. The amount
the guaranteed term is multiplied by this MVA.					withdrawn			from the	guaranteed term is
					multiplied by this MVA.
If a withdrawal or transfer request of a specific dollar
amount is requested, the amount withdrawn from a					If a withdrawal or transfer request of a specific
guaranteed term will be decreased to reflect the					dollar amount is requested, the amount
positive MVA amount. For example, a withdrawal					withdrawn from a guaranteed term will be
request to receive a check for $2,000 would result in a					decreased to reflect the positive MVA amount.
$1,905.49 withdrawal from the guaranteed term.					For example, a withdrawal request to receive a
					check for $2,000 would result in a $1,951.98
					withdrawal from the guaranteed term.




PRO.GAA-11				23


Appendix II

	Examples of Market Value Adjustment at Various Yields

The following hypothetical examples show the market value adjustment (“MVA”) at time of withdrawal for various
times remaining in the guaranteed term, based on:
·	Method One, which uses the current and average corporate bond yields (US Treasury Rate plus spread over
	Treasury) in the MVA calculations; and
·	Method Two, which uses the current and deposit period yields in the MVA calculations,

Table A illustrates the application of the market value adjustment based on an average corporate bond yield or
deposit period yield of the month of deposit of 6%; Table B illustrates the application of the market value
adjustment based on an average corporate bond yield or deposit period yield of the month of deposit of 5%. The
market value adjustment will have either a positive or negative influence on the amount withdrawn from or
remaining in a guaranteed term. Also, the amount of the market value adjustment generally decreases as the end of
the guaranteed term approaches.

TABLE A: Average Corporate Bond Yield or Deposit Period Yield of the Month of Deposit of 6%

		Change in
	Current	Average
Corporate		Corporate
Bond Yield		Bond Yield or
or Current		Deposit
	Yield at	Period Yield
	Time of	of the Month			Time Remaining to
Withdrawal		of Deposit			Maturity of Guaranteed Term
								3 Months
			8 Years	6 Years	4 Years	2 Years	1 Year
	9%	+3%	80.0%	84.6%	89.4%	94.6%	97.2%	99.3%
	8%	+2%	86.1%	89.4%	92.8%	96.3%	98.1%	99.5%
	7%	+1%	92.8%	94.5%	96.3%	98.1%	99.1%	99.8%
	6%	0%	100.0%	100.0%	100.0%	100.0%	100.0%	100.0%
	4%	-2%	116.5%	112.1%	107.9%	103.9%	101.9%	100.5%
	3%	-3%	125.8%	118.8%	112.2%	105.9%	102.9%	100.7%
	2%	-4%	136.0%	126.0%	116.6%	108.0%	103.9%	101.0%
	1%	-5%	147.2%	133.6%	121.3%	110.1%	105.0%	101.2%


TABLE B: Average Corporate Bond Yield or Deposit Period Yield of the Month of Deposit of 5%

		Change in
	Current	Average
Corporate		Corporate
Bond Yield		Bond Yield or
or Current		Deposit
	Yield at	Period Yield
	Time of	of the Month			Time Remaining to
Withdrawal		of Deposit			Maturity of Guaranteed Term
			8 Years	6 Years		2 Years	1 Year	3 Months
					4 Years
	9%	+4%	74.1%	79.9%	86.1%	92.8%	96.3%	99.1%
	8%	+3%	79.8%	84.4%	89.3%	94.5%	97.2%	99.3%
	7%	+2%	86.0%	89.3%	92.7%	96.3%	98.1%	99.5%
	6%	+1%	92.7%	94.5%	96.3%	98.1%	99.1%	99.8%
	4%	-1%	108.0%	105.9%	103.9%	101.9%	101.0%	100.2%
	3%	-2%	116.6%	112.2%	108.0%	103.9%	101.9%	100.5%
	2%	-3%	126.1%	119.0%	112.3%	106.0%	102.9%	100.7%
	1%	-4%	136.4%	126.2%	116.8%	108.1%	104.0%	101.0%




PRO.GAA-11				24

PART II

INFORMATION NOT REQUIRED IN PROSPECTUS

Item 13. Other Expenses of Issuance and Distribution

Not Applicable

Item 14. Indemnification of Directors and Officers

Section 33-779 of the Connecticut General Statutes (“CGS”) provides that a corporation may

provide indemnification of or advance expenses to a director, officer, employee or agent only as

permitted by Sections 33-770 to 33-778, inclusive, of the CGS. Reference is hereby made to

Section 33-771(e) of the CGS regarding indemnification of directors and Section 33-776(d) of

CGS regarding indemnification of officers, employees and agents of Connecticut corporations.

These statutes provide in general that Connecticut corporations incorporated prior to January 1,

1997 shall, except to the extent that their certificate of incorporation expressly provides

otherwise, indemnify their directors, officers, employees and agents against “liability” (defined

as the obligation to pay a judgment, settlement, penalty, fine, including an excise tax assessed

with respect to an employee benefit plan, or reasonable expenses incurred with respect to a

proceeding) when (1) a determination is made pursuant to Section 33-775 that the party seeking

indemnification has met the standard of conduct set forth in Section 33-771 or (2) a court has

determined that indemnification is appropriate pursuant to Section 33-774. Under Section 33-

775, the determination of and the authorization for indemnification are made (a) by two or more

disinterested directors, as defined in Section 33-770(3); (b) by special legal counsel; (c) by the

shareholders; or (d) in the case of indemnification of an officer, agent or employee of the

corporation, by the general counsel of the corporation or such other officer(s) as the board of

directors may specify. Also, Section 33-772 with Section 33-776 provide that a corporation shall

indemnify an individual who was wholly successful on the merits or otherwise against

reasonable expenses incurred by him in connection with a proceeding to which he was a party

because he is or was a director, officer, employee, or agent of the corporation. Pursuant to

Section 33-771(d), in the case of a proceeding by or in the right of the corporation or with

respect to conduct for which the director, officer, agent or employee was adjudged liable on the

basis that he received a financial benefit to which he was not entitled, indemnification is limited

to reasonable expenses incurred in connection with the proceeding against the corporation to

which the individual was named a party.

A corporation may procure indemnification insurance on behalf of an individual who is or was a

director of the corporation. Consistent with the laws of the State of Connecticut, ING America

Insurance Holdings, Inc. maintains Professional Liability and fidelity bond insurance policies

issued by an international insurer. The policies cover ING America Insurance Holdings, Inc. and

any company in which ING America Insurance Holdings, Inc. has a controlling financial interest

of 50% or more. These policies include either or both the principal underwriter, the depositor

and any/all assets under the care, custody and control of ING America Insurance Holdings, Inc.

and/or its subsidiaries. The policies provide for the following types of coverage: errors and

omissions/professional liability, employment practices liability and fidelity/crime (a.k.a.

"Financial Institutional Bond").


Section 20 of the ING Financial Advisers, LLC Limited Liability Company Agreement executed
as of November 28, 2000 provides that ING Financial Advisers, LLC will indemnify certain
persons against any loss, damage, claim or expenses (including legal fees) incurred by such
person if he is made a party or is threatened to be made a party to a suit or proceeding because he
was a member, officer, director, employee or agent of ING Financial Advisers, LLC, as long as
he acted in good faith on behalf of ING Financial Advisers, LLC and in a manner reasonably
believed to be within the scope of his authority. An additional condition requires that no person
shall be entitled to indemnity if his loss, damage, claim or expense was incurred by reason of his
gross negligence or willful misconduct. This indemnity provision is authorized by and is
consistent with Title 8, Section 145 of the General Corporation Law of the State of Delaware.

Item 15. Recent Sales of Unregistered Securities

Not Applicable

Item 16. Exhibits and Financial Statement Schedules

(a)	Furnish the exhibits as required by Item 601 of Regulation S-K (§229.601):

	(1)	(a)	Underwriting Agreement dated November 17, 2006 between Aetna Life
			Insurance and Annuity Company and ING Financial Advisers, LLC ·
			Incorporated by reference to Post-Effective Amendment No. 34 to
			Registration Statement on Form N-4 (File No. 033-75996), as filed on
			December 20, 2006.
		(b)	Confirmation of Underwriting Agreement ·Incorporated by reference to
			Registration Statement on Form S-1 (File No. 333-133158), as filed on
			April 10, 2006.
	(2)		Not Applicable
	(3)	(a)	Restated Certificate of Incorporation (amended and restated as of October 1,
			2007) of ING Life Insurance and Annuity Company ·Incorporated by
			reference to ING Life Insurance and Annuity Company annual report on
			Form 10-K (File No. 033-23376), as filed on March 31, 2008.
		(b)	Amended and Restated By-Laws of ING Life Insurance and Annuity
			Company, effective October 1, 2007 ·Incorporated by reference to ING
			Life Insurance and Annuity Company annual report on Form 10-K (File No.
			033-23376), as filed on March 31, 2008.
	(4)	Instruments Defining the Rights of Security Holders ·Incorporated by reference to
		Post-Effective Amendment No. 1 to Registration Statement on Form S-1 (File No.
		033-60477), as filed on April 15, 1996.
		(a)	Variable Annuity Contract (G-CDA-HF) ·Incorporated by reference to
			Post-Effective Amendment No. 14 to Registration Statement on Form N-4
			(File No. 033-75964), as filed on July 29, 1997.


(b)	Variable Annuity Contract Certificate (GTCC-HF) ·Incorporated by
	reference to Post-Effective Amendment No. 6 to Registration Statement on
	Form N-4 (File No. 033-75980), as filed on February 12, 1997.
(c)	Variable Annuity Contract (GIT-CDA-HO) ·Incorporated by reference to
	Post-Effective Amendment No. 12 to the Registration Statement on Form
	N-4 (File No. 033-75964), as filed on February 11, 1997.
(d)	Variable Annuity Contract (G-CDA-IA(RP)) ·Incorporated by reference to
	Post-Effective Amendment No. 5 to the Registration Statement on Form N-
	4 (File No. 033-75986), as filed on April 12, 1996.
(e)	Variable Annuity Contract Certificate (GTCC-IA(RP)) ·Incorporated by
	reference to Post-Effective Amendment No. 11 to Registration Statement on
	Form N-4 (File No. 333-01107), as filed on February 4, 1999.
(f)	Variable Annuity Contract (G-CDA(12/99)) ·Incorporated by reference to
	Post-Effective Amendment No. 19 to Registration Statement on Form N-4
	(File No. 333-01107), as filed on February 16, 2000.
(g)	Variable Annuity Contract Certificate (C-CDA(12/99)) ·Incorporated by
	reference to Post-Effective Amendment No. 19 to Registration Statement on
	Form N-4 (File No. 333-01107), as filed on February 16, 2000.
(h)	Variable Annuity Contract (GLIT-CDA-HO) ·Incorporated by reference to
	Post-Effective Amendment No. 12 to the Registration Statement on Form
	N-4 (File No. 033-75964), as filed on February 11, 1997.
(i)	Variable Annuity Contract (GST-CDA-HO) ·Incorporated by reference to
	Post-Effective Amendment No. 12 to the Registration Statement on Form
	N-4 (File No. 033-75964), as filed on February 11, 1997.
(j)	Variable Annuity Contract (IP-CDA-IB) ·Incorporated by reference to
	Post-Effective Amendment No. 4 to Registration Statement on Form N-4
	(File No. 033-75988), as filed on April 15, 1996.
(k)	Variable Annuity Contract (I-CDA-IA(RP)) ·Incorporated by reference to
	Post-Effective Amendment No. 5 to the Registration Statement on Form N-
	4 (File No. 033-75986), as filed on April 12, 1996.
(l)	Variable Annuity Contract (I-CDA-HD) ·Incorporated by reference to
	Post-Effective Amendment No. 12 to the Registration Statement on Form
	N-4 (File No. 033-75964), as filed on February 11, 1997.
(m)	Variable Annuity Contract (GIH-CDA-HB) ·Incorporated by reference to
	Post-Effective Amendment No. 6 to Registration Statement on Form N-4
	(File No. 033-75980), as filed on February 12, 1997.
(n)	Variable Annuity Contract (IMT-CDA-HO) ·Incorporated by reference to
	Post-Effective Amendment No. 6 to Registration Statement on Form N-4
	(File No. 033-75980), as filed on February 12, 1997.
(o)	Variable Annuity Contract (G-401-IB(X/M)) ·Incorporated by reference to
	Post-Effective Amendment No. 3 to Registration Statement on Form N-4
	(File No. 033-81216), as filed on April 7, 1996.


(p)	Variable Annuity Contract (G-CDA-IB(XC/SM)) ·Incorporated by
	reference to Post-Effective Amendment No. 3 to Registration Statement on
	Form N-4 (File No. 033-81216), as filed on April 7, 1996.
(q)	Variable Annuity Contracts (G-CDA-IB(ATORP)) and (G-CDA-
	IB(AORP)) ·Incorporated by reference to Post-Effective Amendment No. 3
	to Registration Statement on Form N-4 (File No. 033-91846), as filed on
	April 15, 1996.
(r)	Variable Annuity Contract (G-CDA-96(TORP)) · Incorporated by reference
	to Post-Effective Amendment No. 6 to Registration Statement on Form N-4
	(File No. 033-91846), as filed on August 6, 1996.
(s)	Group Combination Annuity Contract (Nonparticipating) (A001RP95) ·
	Incorporated by reference to Registration Statement on Form N-4 (File No.
	333-01107), as filed on February 21, 1996.
(t)	Group Combination Annuity Certificate (Nonparticipating) (A007RC95) ·
	Incorporated by reference to Registration Statement on Form N-4 (File No.
	333-01107), as filed on February 21, 1996.
(u)	Group Combination Annuity Certificate (Nonparticipating) (A020RV95) ·
	Incorporated by reference to Registration Statement on Form N-4 (File No.
	333-01107), as filed on February 21, 1996.
(v)	Group Combination Annuity Certificate (Nonparticipating) (A027RV95) ·
	Incorporated by reference to Registration Statement on Form N-4 (File No.
	333-01107), as filed on February 21, 1996.
(w)	Variable Annuity Contract (GID-CDA-HO) ·Incorporated by reference to
	Post-Effective Amendment No. 12 to Registration Statement on Form N-4
	(File No. 033-75982), as filed on February 20, 1997.
(x)	Variable Annuity Contract (GSD-CDA-HO) ·Incorporated by reference to
	Post-Effective Amendment No. 12 to Registration Statement on Form N-4
	(File No. 033-75982), as filed on February 20, 1997.
(y)	Variable Annuity Contract (IST-CDA-HO) ·Incorporated by reference to
	Post-Effective Amendment No. 7 to Registration Statement on Form N-4
	(File No. 033-75992), as filed on February 13, 1997.
(z)	Variable Annuity Contract (I-CDA-HD(XC)) ·Incorporated by reference to
	Post-Effective Amendment No. 7 to Registration Statement on Form N-4
	(File No. 033-75992), as filed on February 13, 1997.
(aa)	Variable Annuity Contract (HR1O-DUA-GIA) ·Incorporated by reference
	to Post-Effective Amendment No. 6 to Registration Statement on Form N-4
	(File No. 033-75974), as filed on February 28, 1997.
(bb)	Variable Annuity Contract (GA-UPA-GO) ·Incorporated by reference to
	Post-Effective Amendment No. 6 to Registration Statement on Form N-4
	(File No. 033-75974), as filed on February 28, 1997.
(cc)	Variable Annuity Contracts (G-TDA-HH(XC/M)) and (G-TDA-HH(XC/S)) ·
	Incorporated by reference to Post-Effective Amendment No. 6 to Registration
	Statement on Form N-4 (File No. 033-75962), as filed on April 17, 1996.


(dd)	Variable Annuity Certificate (GTCC-HH(XC/M)) ·Incorporated by
	reference to Post-Effective Amendment No. 14 to Registration Statement on
	Form N-4 (File No. 033-75962), as filed on April 17, 1998.
(ee)	Variable Annuity Certificate (GTCC-HH(XC/S)) ·Incorporated by
	reference to Post-Effective Amendment No. 14 to Registration Statement on
	Form N-4 (File No. 033-75962), as filed on April 17, 1998.
(ff)	Variable Annuity Contract (IA-CDA-IA) ·Incorporated by reference to
	Post-Effective Amendment No. 14 to Registration Statement on Form N-4
	(File No. 033-75964), as filed on July 29, 1997.
(gg)	Variable Annuity Contract (GLID-CDA-HO) ·Incorporated by reference to
	Post-Effective Amendment No. 12 to Registration Statement on Form N-4
	(File No. 033-75982), as filed on February 20, 1997.
(hh)	Variable Annuity Contract (G-CDA-HD) ·Incorporated by reference to
	Post-Effective Amendment No. 6 to Registration Statement on Form N-4
	(File No. 033-75982), as filed on April 22, 1996.
(ii)	Variable Annuity Contract Certificate (GTCC-HD) ·Incorporated by
	reference to Post-Effective Amendment No. 11 to Registration Statement on
	Form N-4 (File No. 333-01107), as filed on February 4, 1999.
(jj)	Variable Annuity Contract (G-CDA-IA(RPM/XC)) ·Incorporated by
	reference to Post-Effective Amendment No. 12 to the Registration
	Statement on Form N-4 (File No. 033-75964), as filed on February 11,
	1997.
(kk)	Variable Annuity Contracts and Certificate (G-CDA-95(ORP)),
	(G-CDA-95(TORP)) and (GTCC-95 (ORP)) ·Incorporated by reference to
	Post-Effective Amendment No. 3 to Registration Statement on Form N-4
	(File No. 033-91846), as filed on April 15, 1996.
(ll)	Variable Annuity Contracts and Certificate (G-CDA-ORP), (CDA-
	IB(TORP)) and (GTCC-95(TORP)) ·Incorporated by reference to Post-
	Effective Amendment No. 3 to Registration Statement on Form N-4 (File
	No. 033-91846), as filed on April 15, 1996.
(mm)	Variable Annuity Contract (IRA-CDA-IC) ·Incorporated by reference to
	Post-Effective Amendment No. 5 to the Registration Statement on Form N-
	4 (File No. 033-75986), as filed on April 12, 1996.
(nn)	Variable Annuity Contract (GIP-CDA-HB) ·Incorporated by reference to
	Post-Effective Amendment No. 8 to Registration Statement on Form N-4
	(File No. 033-75980), as filed on August 19, 1997.
(oo)	Variable Annuity Contract (I-CDA-98(ORP)) ·Incorporated by reference to
	Post-Effective Amendment No. 11 to Registration Statement on Form N-4
	(File No. 333-01107), as filed on February 4, 1999.
(pp)	Variable Annuity Contract (G-CDA-99(NY)) ·Incorporated by reference to
	Post-Effective Amendment No. 19 to Registration Statement on Form N-4
	(File No. 333-01107), as filed on February 16, 2000.


(qq)	Variable Annuity Contract Certificate (C-CDA-99(NY)) ·Incorporated by
	reference to Post-Effective Amendment No. 19 to Registration Statement on
	Form N-4 (File No. 333-01107), as filed on February 16, 2000.
(rr)	Variable Annuity Contract Certificate (GDCC-HF) ·Incorporated by
	reference to Post-Effective Amendment No. 19 to Registration Statement on
	Form N-4 (File No. 333-01107), as filed on February 16, 2000.
(ss)	Variable Annuity Contract Certificate (GDCC-HD) ·Incorporated by
	reference to Post-Effective Amendment No. 19 to Registration Statement on
	Form N-4 (File No. 333-01107), as filed on February 16, 2000.
(tt)	Variable Annuity Contract (G-CDA-HD(XC) ·Incorporated by reference to
	Post-Effective Amendment No. 19 to Registration Statement on Form N-4
	(File No. 333-01107), as filed on February 16, 2000.
(uu)	Variable Annuity Contract Certificate (GDCC-HO) ·Incorporated by
	reference to Post-Effective Amendment No. 19 to Registration Statement on
	Form N-4 (File No. 333-01107), as filed on February 16, 2000.
(vv)	Variable Annuity Contract Certificate (GDCC-HD(XC)) ·Incorporated by
	reference to Post-Effective Amendment No. 19 to Registration Statement on
	Form N-4 (File No. 333-01107), as filed on February 16, 2000.
(ww)	Variable Annuity Contract Certificate (GTCC-HD(XC)) ·Incorporated by
	reference to Post-Effective Amendment No. 19 to Registration Statement on
	Form N-4 (File No. 333-01107), as filed on February 16, 2000.
(xx)	Variable Annuity Contract Certificate (GTCC-HO) ·Incorporated by
	reference to Post-Effective Amendment No. 19 to Registration Statement on
	Form N-4 (File No. 333-01107), as filed on February 16, 2000.
(yy)	Variable Annuity Contract Certificate (GTCC-96(ORP)) ·Incorporated by
	reference to Post-Effective Amendment No. 19 to Registration Statement on
	Form N-4 (File No. 333-01107), as filed on February 16, 2000.
(zz)	Variable Annuity Contract G-CDA-96(ORP)) ·Incorporated by reference
	to Post-Effective Amendment No. 19 to Registration Statement on Form N-
	4 (File No. 333-01107), as filed on February 16, 2000.
(a1)	Variable Annuity Contract Certificate (GTCC-96(TORP)) ·Incorporated by
	reference to Post-Effective Amendment No. 19 to Registration Statement on
	Form N-4 (File No. 333-01107), as filed on February 16, 2000.
(b1)	Variable Annuity Contract Certificate (GTCC-IB(ATORP)) ·Incorporated
	by reference to Post-Effective Amendment No. 19 to Registration Statement
	on Form N-4 (File No. 333-01107), as filed on February 16, 2000.
(c1)	Variable Annuity Contract Certificate (GTCC-IB(AORP) ·Incorporated by
	reference to Post-Effective Amendment No. 19 to Registration Statement on
	Form N-4 (File No. 333-01107), as filed on February 16, 2000.
(d1)	Variable Annuity Contract (ISE-CDA-HO) ·Incorporated by reference to
	Post-Effective Amendment No. 21 to Registration Statement on Form N-4
	(File No. 033-75996), as filed on February 16, 2000.


	(e1)	Variable Annuity Contract (G-CDA-IB(ORP)) ·Incorporated by reference
		to Post-Effective Amendment No. 3 to Registration Statement on Form N-4
		(File No. 033-91846), as filed on April 15, 1996.
	(f1)	Variable Annuity Contract (G-CDA-IB(TORP)) · Incorporated by reference
		to Post-Effective Amendment No. 3 to Registration Statement on Form N-4
		(File No. 033-91846), as filed on April 15, 1996.
	(g1)	Variable Annuity Contract (G-CDA-01(NY)) ·Incorporated by reference to
		Post-Effective Amendment No. 1 to Registration Statement on Form S-2
		(File No. 333-60016), as filed on April 5, 2002.
	(h1)	Variable Annuity Contract Certificate (C-CDA-01(NY)) ·Incorporated by
		reference to Post-Effective Amendment No. 1 to Registration Statement on
		Form S-2 (File No. 333-60016), as filed on April 5, 2002.
	(i1)	Variable Annuity Contract (G-CDA-10) ·Incorporated by reference to
		Post-Effective Amendment No. 16 to Registration Statement on Form N-4
		(File No. 333-109860), as filed on September 17, 2010.
	(j1)	Variable Annuity Contract Certificate (C-CDA-10) ·Incorporated by
		reference to Post-Effective Amendment No. 16 to Registration Statement on
		Form N-4 (File No. 333-109860), as filed on September 17, 2010.
	(k1)	Endorsement E-403bR-09 to Contracts G-CDA-HF, GIT-CDA-HO, G-
		CDA-IA(RP), G-CDA-(12/99), GLIT-CDA-HO, GST-CDA-HO, I-CDA-
		HD, IMT-CDA-HO, G-CDA-IB(XC/SM), G-CDA-IB(ATORP), G-CDA-
		96(TORP), IST-CDA-HO, G-TDA-HH(XC/M), G-TDA-HH(XC/S), IA-
		CDA-IA, G-CDA-HD, G-CDA-IA(RPM/XC), G-CDA-99(NY), G-CDA-
		HD(XC), G-CDA-IB(TORP) and G-CDA-01(NY) and Group Contract
		A001RP95 and Certificates GTCC-HF, GTCC-IA(RP), C-CDA-(12/99),
		GTCC-HH(XC/M), GTCC-HD, GTCC-HD(XC), GTCC-HO, GTCC-
		96(TORP), GTCC-IB(ATORP) and C-CDA-01(NY) and Group Certificates
		A007RC95 and A020RV95 ·Incorporated by reference to Registration
		Statement on Form S-1 or ING Life Insurance and Annuity Company (File
		No. 333-158492), as filed on April 8, 2009.
	(l1)	Endorsement E-403bTERM-08 to Contracts G-CDA-HF, GIT-CDA-HO, G-
		CDA-IA(RP), G-CDA-(12/99), GLIT-CDA-HO, GST-CDA-HO, I-CDA-
		HD, IMT-CDA-HO, G-CDA-IB(XC/SM), G-CDA-IB(ATORP), G-CDA-
		96(TORP), IST-CDA-HO, G-TDA-HH(XC/M), G-TDA-HH(XC/S), IA-
		CDA-IA, G-CDA-HD, G-CDA-IA(RPM/XC), G-CDA-99(NY), G-CDA-
		HD(XC), G-CDA-IB(TORP) and G-CDA-01(NY) and Group Contract
		A001RP95 and Certificates GTCC-HF, GTCC-IA(RP), C-CDA-(12/99),
		GTCC-HH(XC/M), GTCC-HD, GTCC-HD(XC), GTCC-HO, GTCC-
		96(TORP), GTCC-IB(ATORP) and C-CDA-01(NY) and Group Certificates
		A007RC95 and A020RV95 ·Incorporated by reference to Registration
		Statement on Form S-1 or ING Life Insurance and Annuity Company (File
		No. 333-158492), as filed on April 8, 2009.
(5)	Opinion re Legality


	(21)	Subsidiaries of the Registrant
	(23)	(a)	Consent of Independent Registered Public Accounting Firm
		(b)	Consent of Legal Counsel (included in Exhibit (5) above)
	(24)	(a)	Powers of Attorney Included in signature page of this Registration.
		(b)	Certificate of Resolution Authorizing Signature by Power of Attorney ·
			Incorporated by reference to Post-Effective Amendment No. 5 to the
			Registration Statement on Form N-4 (File No. 033-75986), as filed on April
			12, 1996.

Exhibits other than those listed above are omitted because they are not required or are not
applicable.

(b)	ING Life Insurance and Annuity Company Form 10-K for the fiscal year ended
	December 31, 2010 is incorporated in Part I within the Prospectus.


Item 17. Undertakings

The undersigned registrant hereby undertakes as follows, pursuant to Item 512 of Regulation
S-K:

	(a) Rule 415 offerings:

	(1)		To file, during any period in which offers or sales of the registered securities are
			being made, a post-effective amendment to this registration statement:

			(i)	To include any prospectus required by Section 10(a)(3) of the Securities
				Act of 1933;

			(ii)	To reflect in the prospectus any facts or events arising after the effective
				date of the registration statement (or the most recent post-effective
				amendment thereof) which, individually or in the aggregate, represent a
				fundamental change in the information set forth in the registration
				statement; and

			(iii)	To include any material information with respect to the plan of
				distribution not previously disclosed in the registration statement or any
				material changes to such information in the registration statement.

	(2)		That, for the purpose of determining any liability under the Securities Act of
			1933, each such post-effective amendment shall be deemed to be a new
			registration statement relating to the securities offered therein, and the offering
			of such securities at that time shall be deemed to be the initial bona fide offering
			thereof.


	(3)	To remove from registration by means of a post-effective amendment any of the
		securities being registered which remain unsold at the termination of the
		offering.

	(4)	Not Applicable

	(5)(i)	Not Applicable

	(5)(ii)	That for, the purpose of determining liability under the Securities Act of 1933 to
		any purchaser, each prospectus filed pursuant to Rule 424(b) as part of a
		registration statement relating to an offering, other than registration statements
		relying on Rule 430B or other than prospectuses filed in reliance on Rule 430A
		shall be deemed to be part of and included in the registration statement as of the
		date it is first used after effectiveness. Provided, however, that no statement
		made in a registration statement or prospectus that is part of the registration
		statement or made in a document incorporated or deemed incorporated by
		reference into the registration statement or prospectus that is part of the
		registration statement will, as to a purchaser with a time of contract of sale prior
		to such first use, supersede or modify any statement that was made in the
		registration statement or prospectus that was part of the registration statement or
		made in any such document immediately prior to such date of first use.

	(6)	That, for the purpose of determining liability of the registrant under the
		Securities Act of 1933 to any purchaser in the initial distribution of the
		securities, the undersigned registrant undertakes that in a primary offering of
		securities of the undersigned registrant pursuant to this registration statement,
		regardless of the underwriting method used to sell the securities to the
		purchaser, if the securities are offered or sold to such purchaser by means of any
		of the following communications, the undersigned registrant will be a seller to
		the purchaser and will be considered to offer or sell such securities to such
		purchaser: (i) any preliminary prospectus or prospectus of the undersigned
		registrant relating to the offering required to be filed pursuant to Rule 424; (ii)
		any free writing prospectus relating to the offering prepared by or on behalf of
		the undersigned registrant or used or referred to by the undersigned registrant;
		(iii) the portion of any other free writing prospectus relating to the offering
		containing material information about the undersigned registrant or its securities
		provided by or on behalf of the undersigned registrant; and (iv) any other
		communication that is an offer in the offering made by the undersigned
		registrant to the purchaser.

(b)	Not Applicable

(c)	Not Applicable

(d)	Not Applicable

(e)	Not Applicable


(f)	Not Applicable

(g)	Not Applicable

(h)	Request for Acceleration of Effective Date:

	Insofar as indemnification for liabilities arising under the Securities Act of 1933 may
	be permitted to directors, officers and controlling persons of the registrant pursuant to
	the foregoing provisions, or otherwise, the registrant has been advised that in the
	opinion of the Securities and Exchange Commission such indemnification is against
	public policy as expressed in the Act and is, therefore, unenforceable. In the event that
	a claim for indemnification against such liabilities (other than the payment by the
	registrant of expenses incurred or paid by a director, officer or controlling person of the
	registrant in the successful defense of any action, suit or proceeding) is asserted by such
	director, officer or controlling person in connection with the securities being registered,
	the registrant will, unless in the opinion of its counsel the matter has been settled by
	controlling precedent, submit to a court of appropriate jurisdiction the question whether
	such indemnification by it is against public policy as expressed in the Act and will be
	governed by the final adjudication of such issue.

(i)	Not Applicable

(j)	Not Applicable

(k)	Not Applicable

(l)	Not Applicable


	SIGNATURES

Pursuant to the requirements of the Securities Act of 1933, the Registrant has duly caused this
Registration Statement on Form S-1 to be signed on its behalf by the undersigned, thereunto duly
authorized in the City of New York, State of New York, on this 1st day of April, 2011.

	By:	ING LIFE INSURANCE AND ANNUITY
		COMPANY
		(REGISTRANT)

	By:	/s/ Robert G. Leary
		Robert G. Leary
		President
		(principal executive officer)

As required by the Securities Act of 1933, this Registration Statement has been signed by the
following persons in the capacities and on the dates indicated. Each person whose signature appears
below hereby constitutes and appoints J. Neil McMurdie, Julie E. Rockmore and Nicholas Morinigo,
and each of them individually, such person's true and lawful attorneys and agents with full power of
substitution and resubstitution for him or her and in his or her name, place and stead, in any and all
capacities, to sign for such person and in such person's name and capacity indicated below, any and all
amendments to this Registration Statement, hereby ratifying and confirming such person's signatures
as it may be signed by said attorneys to any and all amendments (pre-effective and post-effective
amendments).

Signature	Title			Date

/s/Robert G. Leary	President and Director		)	April 1, 2011
Robert G. Leary	(principal executive officer)		)
			)
/s/Patrick G. Flynn	Director and Chairman		)	February 24, 2011
Patrick G. Flynn			)
			)
/s/Lynne R. Ford	Director and Executive Vice President		)	February 25, 2011
Lynne R. Ford			)
			)
/s/Ewout L. Steenbergen	Director, Executive Vice President and		)	March 8, 2011
Ewout L. Steenbergen	Chief Financial Officer		)
			)
/s/Michael S. Smith	Director		)	February 25, 2011
Michael S. Smith			)
			)
/s/ Donald Britton	Director		)	February 25, 2011
Donald W. Britton			)
			)


/s/Steven T. Pierson	Senior Vice President and Chief Accounting Officer	) February 25, 2011
Steven T. Pierson		)


State of New York
County of New York

On the 1st day of April in the year 2011, before me, the undersigned, personally appeared Robert
G. Leary, personally known to me or proved to me on the basis of satisfactory evidence to be the
individual whose name is subscribed to the within instrument and acknowledged to me that he
executed the same in his capacity, and that by his signature on the instrument, the individual, or
the person upon behalf of which the individual acted, executed the instrument.

/s/ Helen M. Scheuer	Helen M. Scheuer
Notary Public	Notary Public, State of New York
	No. 01SC3352985
	Qualified in New York County
	Commission Expires 4-30-2011



State of New York
County of New York

On the 25th day of February in the year 2011, before me, the undersigned, personally appeared Lynne R.
Ford, personally known to me or proved to me on the basis of satisfactory evidence to be the individual
whose name is subscribed to the within instrument and acknowledged to me that she executed the same in
her capacity, and that by her signature on the instrument, the individual, or the person upon behalf of
which the individual acted, executed the instrument.

/s/ Helen M. Scheuer	Helen M. Scheuer
Notary Public	Notary Public, State of New York
	No. 01SC3352985
	Qualified in New York County
	Commission Expires 4-30-2011

On the 8th day of March in the year 2011, before me, the undersigned, personally appeared
Ewout L. Steenbergen, personally known to me or proved to me on the basis of satisfactory
evidence to be the individual whose name is subscribed to the within instrument and
acknowledged to me that he executed the same in his capacity, and that by his signature on the
instrument, the individual, or the person upon behalf of which the individual acted, executed the
instrument.

/s/ Helen M. Scheuer	Helen M. Scheuer
Notary Public	Notary Public, State of New York
	No. 01SC3352985
	Qualified in New York County
	Commission Expires 4-30-2011

CAUTION TO THE PRINCIPAL: Your Power of Attorney is an important document. As the

“principal,” you give the person whom you choose (your “agent”) authority to spend your money

and sell or dispose of your property during your lifetime without telling you. You do not lose

your authority to act even though you have given your agent similar authority.

When your agent exercises this authority, he or she must act according to any instructions you

have provided or, where there are no specific instructions, in your best interest. “Important

Information for the Agent” at the end of this document describes your agent’s responsibilities.

Your agent can act on your behalf only after signing the Power of Attorney before a notary

public.

You can request information from your agent at any time. If you are revoking a prior Power of

Attorney by executing this Power of Attorney, you should provide written notice of the

revocation to your prior agent(s) and to the financial institutions where your accounts are

located.

You can revoke or terminate your Power of Attorney at any time for any reason as long as you

are of sound mind. If you are no longer of sound mind, a court can remove an agent for acting

improperly.

Your agent cannot make health care decisions for you. You may execute a “Health Care Proxy”

to do this.

The law governing Powers of Attorney is contained in the New York General Obligations Law,

Article 5, Title 15. This law is available at a law library, or online through the New York State

Senate or Assembly websites, www.senate.state.ny.us or www.assembly.state.ny.us.

If there is anything about this document that you do not understand, you should ask a lawyer of

your own choosing to explain it to you.


Signature of Agents:


State of Pennsylvania
/s/ Nicholas Morinigo	County of Chester
Nicholas Morinigo
	On this, the 31st day of March, 2011, before me
	Tabitha E. Muniz, the undersigned officer, personally appeared
Commonwealth of Pennsylvania	Nicholas Morinigo, known to me (or satisfactorily proven) to
Notarial Seal	be the person whose name is subscribed as attorney in fact for
Tabitha E. Muniz, Notary Public	Robert G. Leary, Lynne R. Ford and Ewout L. Steenbergen, and
West Whiteland Twp., Chester County	acknowledged that he executed the same as the act of his
My Commission Expires Dec. 10,	principal for the purposes therein contained.
2014
/s/ Tabitha E. Muniz

	Notary Public


State of Connecticut
/s/ J. Neil McMurdie	County of Hartford Town of Windsor
J. Neil McMurdie
	The foregoing instrument was executed and acknowledged
	before me this 25th day of March, 2011, by J. Neil McMurdie,
Nicole L. Molleur	as attorney in fact on behalf of Robert G. Leary, Lynne R. Ford
Notary Public Within and for	and Ewout L. Steenbergen.
The State of Connecticut
My commission expires: Nov. 30,	/s/ Nicole L. Molleur
2014	Notary Public



State of Connecticut
/s/ Julie Rockmore	County of Hartford Town of Windsor
Julie Rockmore
	The foregoing instrument was executed and acknowledged
	before me this 23rd day of March, 2011, by Julie Rockmore, as
Nicole L. Molleur	attorney in fact on behalf of Robert G. Leary, Lynne R. Ford
Notary Public Within and for	and Ewout L. Steenbergen.
The State of Connecticut
My commission expires: Nov. 30,	/s/ Nicole L. Molleur
2014	Notary Public

IMPORTANT INFORMATION FOR THE AGENT:

When you accept the authority granted under this Power of Attorney, a special legal relationship

is created between you and the principal. This relationship imposes on you legal responsibilities

that continue until you resign or the Power of Attorney is terminated or revoked. You must:

(1) act according to any instructions from the principal, or, where there are no instructions, in the

principal’s best interest;

(2) avoid conflicts that would impair your ability to act in the principal’s best interest;

(3) keep the principal’s property separate and distinct from any assets you own or control, unless

otherwise permitted by law;

(4) keep a record of all receipts, payments, and transactions conducted for the principal; and

(5) disclose your identity as an agent whenever you act for the principal by writing or printing

the principal’s name and signing your own name as “agent” in either of the following manner:

(Principal’s Name) by (Your Signature) as Agent, or (your signature as Agent for (Principal’s

Name).

You may not use the principal’s assets to benefit yourself or give major gifts to yourself or

anyone else unless the principal has specifically granted you that authority in this Power of

Attorney or in a Statutory Major Gifts Rider attached to this Power of Attorney. If you have that

authority, you must act according to any instructions of the principal or, where there are no such

instructions, in the principal’s best interest.; You may resign by giving written notice to the

principal and to any co-agent, successor agent, monitor if one has been named in this document,

or the principal’s guardian if one has been appointed. If there is anything about this document or

your responsibilities that you do not understand, you should seek legal advice.

Liability of the agent:

The meaning of the authority given to you is defined in New York’s General Obligations Law,

Article 5, Title 15. If it is found that you have violated the law or acted outside the authority

granted to you in the Power of Attorney, you may be liable under the law for your violation.


You may request a free copy of any documents incorporated by reference in this prospectus (including any exhibits
that are specifically incorporated by reference in them). Please direct your request to:

ING Life Insurance and Annuity Company
Customer Service Center
One Orange Way
Windsor, CT 06095-4774
1-800-262-3862




*Inquiries*

You may contact us directly by writing or calling to us at the address or phone number shown above.




PRO.GAA-11	19


	EXHIBIT INDEX
Exhibit No.	Exhibit
16(a)(5)	Opinion re: Legality
16(a)(21)	Subsidiaries of the Registrant
16(a)(23)(a)	Consent of Independent Registered Public Accounting Firm
16(a)(23)(b)	Consent of Legal Counsel	*
16(a)(24)(a)	Powers of Attorney	**

*Included in Exhibit 16(a)(5) above
**Included on signature page of this Registration