NOTES TO FINANCIAL STATEMENTS
DISTRIBUTION PLAN AND SHAREHOLDER SERVICING PLAN
The Trust, on behalf of the Funds, has adopted a Plan of Distribution pursuant to Rule 12b-1 under the
Investment Company Act. Each Fund pays ING Funds Distributor, Inc. (the "Distributor") monthly, based on an
annual rate of up to 0.50% of average daily net assets attributable to the Funds' Class A shares and 0.75% of
average daily net assets attributable to the Funds' Class B, C, and X shares. The distribution fee for all classes
may be used by the Distributor for the purpose of financing any activity which is primarily intended to result in the
sale of shares of the applicable Fund.
The Funds have adopted a Shareholder Servicing Plan pursuant to which each may pay a service fee up to an
annual rate of 0.25% of a Fund's average daily net assets to various banks, trust companies, broker-dealers or
other financial organizations including the Manager and its affiliates.
For the period ended October 31, 2000, the Distributor waived part of the distribution fees. The distribution fees
to which the Distributor was entitled, the distribution fees waived, and the shareholder servicing fees are indicated
In addition, the Distributor collects sales charges imposed on sales of each Fund's Class A shares and reallows a
portion of such charges to dealers through which the sales are made. There is also a contingent deferred sales
load ("CDSL") on Class B, C and X shares, which applies if redemption occurs within six years of purchase for
the Class B and X shares and within one year of purchase for the Class C shares. Class A share purchases equal
to or exceeding $1,000,000 in the aggregate, which did not incur an initial sales charge, are subject to a 1.00%
CDSL if redeemed within one year of purchase.
For the period ended October 31, 2000, sales charges and CDSL's paid to the Distributor were approximately:
Distribution Fee Dis