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	Funds

	Annual Report
	February 28, 2007

	ING Risk Managed Natural Resources Fund

	E-Delivery Sign-up – details inside

	This report is submitted for general information to shareholders of the ING Funds. It is not authorized for distribution to prospective shareholders unless accompanied or preceded by a prospectus which includes details regarding the funds’ investment objectives, risks, charges, expenses and other information. This information should be read carefully.

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President’s Letter		1
Market Perspective		2
Portfolio Managers’ Report		4
Report of Independent Registered Public Accounting Firm		6
Statement of Assets and Liabilities		7
Statement of Operations		8
Statement of Changes in Net Assets		9
Financial Highlights		10
Notes to Financial Statements		11
Portfolio of Investments		21
Tax Information		25
Trustee and Officer Information		26
Advisory Contract Approval Discussion		31
Additional Information		35

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Dear Shareholder,

ING Risk Managed Natural Resources Fund (the “Fund”) is a non-diversified, closed-end management investment company traded on the New York Stock Exchange under the symbol “IRR.” The Fund’s investment objective is total return through a combination of current income, capital gains and capital appreciation.

The Fund will seek to achieve its investment objective by investing in a portfolio of equity securities of companies in the energy and natural resources industries and by employing an integrated options “collar” strategy. The Fund’s collar strategy also seeks to reduce the volatility of the performance of the Fund on a total return basis relative to the natural resources equity sector and to help the Fund achieve its total return investment objective by seeking to generate capital gains in declining markets from the purchase of put options and premiums from writing call options.

Based on its share price as of February 28, 2007, the Fund, since its inception on October 24, 2006, provided a total return of (5.50)%⁽¹⁾. This return reflects a share price of $18.76 on February 28, 2007, plus the reinvestment of $0.14 per share in distributions. Based on net asset value (“NAV”), the Fund had a total return of 1.38%⁽²⁾ for the period. During the period, the Fund paid its initial distribution of $0.142 per share. Following the initial distribution, the Fund intends to implement a level quarterly distribution policy and expects future quarterly distributions to equal $0.425 per share. For more information on the Fund’s performance, please read the Market Perspective and Portfolio Managers’ Report.

At ING Funds our mission is to set the standard in helping our clients manage their financial future. We seek to assist you and your financial advisor by offering a range of global investment solutions. We invite you to visit our website at www.ingfunds.com. Here you will find information on our products and services, including current market data and fund statistics on our open- and closed-end funds. You will see that we offer a broad variety of equity, fixed income and multi-asset funds that aim to fulfill a variety of investor needs.

We thank you for trusting ING Funds with your investment assets, and we look forward to serving you in the months and years ahead.

Sincerely,

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International investing does pose special risks including currency fluctuation, economic and political risks not found in investments that are solely domestic.

¹   Total investment return at market value measures the change in the market value of your investment assuming reinvestment of dividends and capital gain distributions, if any, in accordance with the provisions of the Fund’s dividend reinvestment plan. Total investment return at market value is not annualized for periods less than one year.

²   Total investment return at net asset value has been calculated assuming a purchase at net asset value at the beginning of each period and a sale at net asset value at the end of each period and assumes reinvestment of dividends and capital gain distributions, if any, in accordance with the provisions of the dividend reinvestment plan. Total investment return at net asset value is not annualized for periods less than one year.

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During the six months ended August 31, 2006, global equities markets apparently obsessed by interest rates and how the modest gains for the six-month period were largely made after the U.S. Federal Reserve Board left the federal funds rate unchanged on August 8, 2006 after 17 interest rate increases. The second half of the fiscal year was much healthier however, and the Morgan Stanley Capital International (“MSCI”) World Index^SM(1) measured in local currencies, including net reinvested dividends advanced 9.6% and for the year ended February 28, 2007, returned 15.86%. In currencies, the dollar, suffering from expectations that European interest rates would rise faster than those in the U.S., fell 3.1% in euros and 3.0% against the pound. But the yen was buffeted by the “carry trade”: speculators borrow in yen at tiny interest rates and buy higher yielding securities in other currencies, often leveraged, and riskily betting that the yen will not strengthen. For six months, the dollar gained 1.26% and for the year ended February 28, 2007, the dollar gained 2.12%.

During the six months ended August 31, 2006, the once booming U.S. housing market, a powerful driver of growth in recent years, had fallen into decline and the economy was clearly slowing. This continued into the second six months and it was only in the last few days of 2006 that the slump showed some signs of bottoming out, with unexpectedly good new and existing home sales figures reported, along with rebounding consumer confidence. The early economic data in 2007 sustained this view, reporting strong employment, retail sales and confidence readings as well as robust increases in housing starts and pending home sales. The first estimate of fourth quarter gross domestic product (“GDP”) growth was an impressive 3.5%.

Yet the seeds of doubt were planted when it was reported on February 2, 2007, that the default rate among sub-prime housing loans was now higher than during the 2001 recession. It had long been feared that mortgage lending had become far too easy during the boom, particularly to those least able to repay and that the inevitable correction would be severe. Within weeks the country’s largest sub-prime mortgage lender increased its loss reserves by $1.76 billion, while the apparent general improvement in housing figures proved illusory. This may be explained by the mild weather of early winter, as new starts and sales plummeted and prices resumed their decline. Fourth quarter GDP growth was revised down to 2.2% and the fiscal year ended with fears that the weak conditions would persist for much longer than had been hoped.

Fixed income markets reacted predictably after August. The ten-year U.S. Treasury yield fell to its lowest level at the beginning of December, then soared 47 basis points (0.47%) within two months to its peak, before giving most of it back in February to end at 4.55%, 18 basis points (0.18%) below the August 31, 2006 rate. With the Federal Open Market Committee’s (“FOMC”) bias still towards tightening the yield on the three-month Treasury Bill was more stable during the second six months, rising by 9 basis points (0.09%) to 5.00%. On February 27, 2007, in fact the yield on the three-month Treasury Bill exceeded the ten-year yield by 48 basis points (0.48%), the most since January 2, 2001. The broader Lehman Brothers^® Aggregate Bond Index (“LBAB”)⁽²⁾ of investment grade bonds gained 3.66% and for the year ended February 28, 2007 returned 5.54%.

February was an unsettling month in other ways. The China stock market had practically doubled in 2006 and the long expected pull back eventually came on February 27th when the index fell 9%. The effect on sentiment was to shake relative risk strategies generally. Money left stocks and high yield bonds and went into investment grade bonds. Many carry trades were unwound. The effect on major developed markets and on other Asian emerging markets were falls of between 3.5% to 4.5% at the end of the month.

Investors in U.S. equities remained generally optimistic in the face of growing evidence of economic slowdown and later sub-prime mortgage lending problems. For the second six months of the fiscal year, the Standard & Poor’s 500^® Composite Stock Price Index (“S&P 500^® Index”)⁽³⁾ rose 8.9% and for the year ended February 28, 2007 returned 11.97%, including dividends. Reasons for this were not hard to find. For one thing, the oil price, having hit its record in mid July averaged 22% less. GDP growth may have slowed but the share of corporate profits, reported at 12.4%, was the highest since the 1950s. S&P 500^® Index companies were well on their way to reporting their 14th straight double-digit percentage earnings gain. The next merger or acquisition never seemed far away. The setback on February 27, a 3.5% fall, was the worst in nearly three years.

International markets also had a strong second half (based on MSCI local currency indices plus net

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dividends), subject to sharp drops in the last two days. In Japan the market advanced 9.5% boosted by the fastest quarterly rate of GDP growth in three years and despite another 0.25% interest rate increase in late February. Consumer spending was fragile despite low unemployment and almost flat prices. Yet business confidence remained high and profit growth healthy. European ex UK markets surged 11.3%. The environment for stocks improved, due to the fastest GDP growth in years, inflation just below 2%, declining unemployment and budget deficits, plus continuing merger and acquisition activity, and despite headwinds in the form of a strengthening euro, a hawkish European Central Bank that raised rates twice and the rise in German sales tax. UK equities added 6.2% in the second six months of our fiscal year, shrugging off two rate increases and inflation at 2.8%. Rising home prices, up more than 10% in 2006, and a robust service sector appear to have raised the UK’s growth trajectory, with fourth quarter GDP 3.0% higher than a year earlier. Again however widespread, large-scale mergers and acquisitions energized the market.

⁽²⁾ The LBAB Index is a widely recognized, unmanaged index of publicly issued investment grade U.S. Government, mortgage-backed, asset-backed and corporate debt securities.

⁽³⁾ The S&P 500^® Index is an unmanaged index that measures the performance of the securities of approximately 500 of the largest companies in the U.S.

All indices are unmanaged and investors cannot invest directly in an index.

Past performance does not guarantee future results. The performance quoted represents past performance. Investment return and principal value of an investment will fluctuate, and shares, when redeemed, may be worth more or less than their original cost. The Fund’s performance is subject to change since the period’s end and may be lower or higher than the performance data shown. Please call (800) 992-0180 or log on to www.ingfunds.com to obtain performance data current to the most recent month end.

Market Perspective reflects the views of the Chief Investment Risk Officer only through the end of the period, and is subject to change based on market and other conditions.

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Risk Managed Natural Resources Fund (the “Fund”) seeks total return through a combination of current income, capital gains and capital appreciation. The Fund is managed by Paul Zemsky, James A. Vail, Anthony Socci and Jody I. Hrazanek, Portfolio Managers, ING Investment Management Co. — the Sub-Adviser.

Portfolio Construction: Under normal market conditions, the Fund seeks to achieve its investment objective by investing at least 80% of its managed assets in the equity securities of, or derivatives linked to the equity securities of companies that are primarily engaged in owning or developing energy, other natural resources and basic materials, or supplying goods and services to such companies (“Natural Resources Companies”). Equity securities held by the Fund could include common stocks, preferred shares, convertible securities, warrants and depository receipts. Additionally, the Fund employs an integrated options “collar” strategy which seeks to partially reduce the exposure of the Fund to declines in the value of the energy and natural resources securities in its portfolio and helps the Fund achieve its investment objective by seeking to generate capital gains in declining markets from the purchase of put options and premiums from writing call options.

Equity Portfolio: When selecting equity investments for the Fund, the Sub-Adviser uses fundamental and quantitative research provided by its analysts. The Sub-Adviser normally seeks to identify securities of companies that it believes to be undervalued relative to the value of the energy and natural resources assets they hold or their business fundamentals and outlook. This identification process takes into account current and anticipated economic and financial conditions, as well as company-specific considerations that may cause the issuer’s equity to lead or lag the performance of the broader natural resources investment universe. The Sub-Adviser believes that the best investment

Country Allocation

United States	91.8%

Canada	3.4%

Brazil	0.9%

Netherlands	0.9%

Bermuda	0.8%

Australia	0.5%

France	0.5%

Jersey	0.3%

Papua New Guinea	0.3%

United Kingdom	0.3%

Russia	0.2%

South Africa	0.2%

Other Assets and Liabilities-Net*	(0.1)%

Net Assets	100.0%

*	Includes short-term investments related to repurchase agreement.

Portfolio holdings are subject to change daily.

candidates are those that feature superior capital allocation, strong competitive position and operations in industries with robust demand. Furthermore, the Sub-Adviser favors companies that can grow their production rather than those that simply rely upon strengthening commodity prices to improve their earnings outlooks. In constructing the portfolio, the Sub-Adviser takes into account the objectives of the Fund’s collar strategy and the instruments through which it is implemented. Under normal market conditions, the Fund generally holds approximately 80-120 equity securities in its portfolio.

“Collar” Strategy: Under normal market conditions, the Fund seeks to manage risk by employing an integrated options collar strategy. The Fund’s collar strategy includes: purchasing put options and writing call options on energy and materials indices (“Resource Indices”) and/or exchange-traded funds (“ETFs”), correlated with the Fund’s portfolio, or securities held in the Fund’s portfolio. Under normal market conditions, the Fund generally purchases put options approximately 5% “out-of-the-money,” usually on a three-month basis and for an amount approximating 100% of the value of the Fund’s underlying assets. The Fund usually writes call options “at-the-money” or “near-to-the-money,” usually on a one-month basis and for an amount equal to 50-100% of the value of the Fund’s underlying assets. The Fund’s collar strategy seeks to partially reduce the exposure of the Fund to declines in the value of energy and natural resources securities in its portfolio, while simultaneously generating capital gains in declining markets from the purchase of put options and premiums from writing call options to help the Fund achieve its total return investment objective. Put options may be financed by a portion of the premiums received by the Fund from the sale of call options. The Fund may purchase put options and write call options on Resource Indices and/or ETFs including, but not limited to the Energy Select Sector Index^® and the Materials Select Sector Index^® (each a “Sector Index” and collectively, the “Sector Indices”), and/or the Energy Select Sector SPDR^® Fund and the Materials Select Sector SPDR^® Fund

Top Ten Holdings

ExxonMobil Corp.	14.0%

Chevron Corp.	8.0%

ConocoPhillips	7.1%

Schlumberger Ltd.	3.5%

Occidental Petroleum Corp.	3.0%

Marathon Oil Corp.	2.3%

Valero Energy Corp.	2.2%

Hess Corp.	1.9%

XTO Energy, Inc.	1.9%

EI DuPont de Nemours & Co.	1.7%

Portfolio holdings are subject to change daily.

(each a “SPDR^® Fund” and collectively, the “SPDR^® Funds”). The collar strategy may be executed primarily in over-the-counter markets with major international banks, broker-dealers and financial institutions.

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Performance: Based on its share price as of February 28, 2007, the Fund, since its inception on October 24, 2006, provided a total return of (5.50)%. This return reflects a share price of $18.76 on February 28, 2007, plus the reinvestment of $0.14 per share in distributions. Based on net asset value (“NAV”), the Fund had a total return of 1.38% for the period. The Composite Index (80% Energy Select Sector Index^® (“IXE”) and 20% Materials Select Sector Index^® (“IXB”)) returned 4.57% for the same period. During the period, the Fund made one quarterly distribution of $0.14 per share. As of February 28, 2007, the Fund had 22,609,972 shares outstanding.

Market Commentary: Energy stocks surged in November due largely to a recovery in natural gas prices. In the subsequent three months, these returns were muted by investor concerns over global economic growth, the U.S. sub-prime mortgage market’s impact on the broader U.S. housing industry and a milder winter. The latter put negative pressure on heating oil and natural gas. Within the materials sector, stocks performed well during this period due to continued strength in global demand. For the four months ended February 28, 2007, the IXE Index returned 2.54% while the IXB Index returned 12.46%.

Equity Portfolio Commentary: Since the Fund’s inception, the underlying natural resources portfolio, before expenses, outperformed its index, an 80%/20% blended benchmark of the IXE and IXB. Within energy, the Fund’s investments in exploration and production companies and equipment and service companies aided performance. Cabot Oil and Gas Corp., the Fund’s strongest performer, benefited from technology advancements which allowed it to harvest more gas from new wells in the Appalachia region. The decision to underweight Halliburton Co. and Baker Hughes, Inc. also had a positive impact on the Fund as both companies lost ground to their competitors due to a lack of infrastructure. In addition, stock selection in the gold sub-sector was a positive contributor, particularly Eldorado Gold Corp. and Lihir Gold Ltd., which continue to benefit from higher gold bullion prices. Detracting from relative performance was our position in Evergreen Energy, Inc., a company with a potentially revolutionary coal cleaning process. This stock was hurt by concerns over operational delays during this period.

Option Portfolio Commentary: The Fund’s collar strategy is designed to exploit the high implied volatility of the natural resources sector by attempting to protect the portfolio from large net asset value (“NAV”) draw downs while seeking to provide current income and the potential for upside appreciation. During the period, the Fund purchased put options and wrote call options on the IXE Index and the IXB Index. The put options were purchased against 100% of the underlying assets with strike prices at roughly 5% out of the money and expiration dates averaging three months. The Fund financed the cost of put options and earned premium income by writing call options on an amount equal to approximately 70% of the value of the Fund’s holdings with strike prices at the money and expiration dates averaging one month. As natural resource stocks rose significantly in November, a majority of the puts options purchased to protect he Fund expired without value. Similarly, as a result of the market rally during the quarter, the majority of written call options detracted from the Fund’s relative performance. When equity prices rise, as they did during the period, call options that were sold by the Fund are usually executed by the buyers, and the Fund makes a settlement payment to the buyer based on the difference between the option strike price and the current market price of each underlying security.

Current Strategy and Outlook: The Fund seeks to provide investors with exposure to the natural resources asset class while utilizing an option strategy to reduce downside net asset value volatility and generate an attractive current income stream. If the market falls or moves sideways, the premiums generated from our call-writing strategies, dividends and our disciplined equity strategy may comprise an important part of the Fund’s total return. If the market rallies, the strategy may generate an absolute positive return, but the upside may be limited as call options may likely be exercised. If the market has a significant downturn, our downside will be limited as we will likely exercise the puts. For the coming months, we expect volatility levels to remain steady to slightly higher as concerns over commodity prices persist. We believe implied volatility should be adequate to continue receiving an attractive level of call premium income after using some of the proceeds to pay for our put protection.

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The Shareholders and Board of Trustees

We have audited the accompanying statement of assets and liabilities of ING Risk Managed Natural Resources Fund, including the portfolio of investments, as of February 28, 2007, and the related statements of operations and changes in net assets, and the financial highlights for the period from October 24, 2006 (commencement of operations) to February 28, 2007. These financial statements and financial highlights are the responsibility of management. Our responsibility is to express an opinion on these financial statements and financial highlights based on our audit.

We conducted our audit in accordance with the standards of the Public Company Accounting Oversight Board (United States). Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements and financial highlights are free of material misstatement. An audit includes examining, on a test basis, evidence supporting the amounts and disclosures in the financial statements. Our procedures included confirmation of securities owned as of February 28, 2007, by correspondence with the custodian and brokers, or by other appropriate auditing procedures when replies from brokers were not received. An audit also includes assessing the accounting principles used and significant estimates made by management, as well as evaluating the overall financial statement presentation. We believe that our audit provides a reasonable basis for our opinion.

In our opinion, the financial statements and financial highlights referred to above present fairly, in all material respects, the financial position of ING Risk Managed Natural Resources Fund as of February 28, 2007, and the results of its operations, the changes in its net assets, and the financial highlights for the period specified in the first paragraph above, in conformity with U.S. generally accepted accounting principles.

Boston, Massachusetts

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ASSETS:
Investments in securities at value*				$	434,010,945
Short-term investments at amortized cost					2,572,000
Cash					1,009,732
Foreign currencies at value**					5,178
Receivables:
	Investment securities sold				415,739
	Dividends and interest				1,134,414
Unrealized appreciation on forward foreign currency contracts					103,199
Prepaid expenses					600
		Total assets			439,251,807
LIABILITIES:
Payable for investment securities purchased					1,405,724
Unrealized depreciation on forward foreign currency contracts					6,713
Payable to affiliates					296,355
Payable for trustee fees					8,729
Other accrued expenses and liabilities					367,673
Options written***					3,571,246
		Total liabilities			5,656,440
NET ASSETS (equivalent to $19.18 per share on 22,609,972)				$	433,595,367
NET ASSETS WERE COMPRISED OF:
Paid-in capital — shares of beneficial interest at $0.01 par value (unlimited shares authorized)					428,582,581
Undistributed net investment income					471,483
Accumulated net realized loss on investments, foreign currency related transactions, and written options					(9,821,598	)
Net unrealized appreciation on investments, foreign currency related transactions, and written options					14,362,901
NET ASSETS				$	433,595,367
* Cost of investments in securities				$	422,535,258
** Cost of foreign currencies				$	5,233
*** Premiums received for options written				$	6,361,944

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			October 24, 2006(1)
			to February 28,
			2007
INVESTMENT INCOME:
Dividends, net of foreign taxes withheld*			$	2,688,305
Interest				356,559
	Total investment income			3,044,864
EXPENSES:
Investment management fees				1,454,656
Transfer agent fees				8,729
Administrative service fees				145,464
Shareholder reporting expense				43,644
Registration fees				26,186
Professional fees				24,914
Custody and accounting expense				19,828
Trustee fees				13,885
Organizational costs				70,000
Miscellaneous expense				8,732
	Total expenses			1,816,038
	Net waived fees			(70,000	)
	Net expenses			1,746,038
Net investment income				1,298,826
REALIZED AND UNREALIZED GAIN (LOSS) ON INVESTMENTS, FOREIGN CURRENCY RELATED TRANSACTIONS, AND WRITTEN OPTIONS:
Net realized gain (loss) on:
	Investments			4,064,663
	Foreign currency related transactions			7,564
	Written options			(13,879,444	)
Net realized loss on investments, foreign currency related transactions, and written options				(9,807,217	)
Net change in unrealized appreciation or depreciation on:
	Investments			11,475,687
	Foreign currency related transactions			96,516
	Written options			2,790,698
Net change in unrealized appreciation or depreciation on investments, foreign currency related transactions, and written options				14,362,901
Net realized and unrealized gain on investments, foreign currency related transactions, and written options				4,555,684
Increase in net assets resulting from operations			$	5,854,510
* Foreign taxes withheld			$	15,778
(1) Commencement of operations.

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		October 24, 2006(1)
		to February 28,
		2007
FROM OPERATIONS:
Net investment income		$	1,298,826
Net realized loss on investments, foreign currency related transactions, and written options			(9,807,217	)
Net change in unrealized appreciation or depreciation on investments, foreign currency related transactions, and written options			14,362,901
Net increase in net assets resulting from operations			5,854,510
FROM DISTRIBUTIONS TO SHAREHOLDERS:
Net investment income			(878,027	)
Tax return of capital			(2,331,900	)
Total distributions			(3,209,927	)
FROM CAPITAL SHARE TRANSACTIONS:
Net proceeds from sale of shares(2)			430,756,000
Dividends reinvested			94,784
Net increase in net assets resulting from capital share transactions			430,850,784
Net increase in net assets			433,495,367
NET ASSETS:
Beginning of period			100,000
End of period		$	433,595,367
Undistributed net investment income at end of period		$	471,483

	(1)	Commencement of operations.
	(2)	Proceeds from sales of shares net of sales load paid of $20,340,000 and offering costs of $904,000.

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Selected data for a share of beneficial interest outstanding throughout the period.

				October 24,
				2006(1) to
				February 28,
				2007
Per Share Operating Performance:
Net asset value, beginning of period		$			19.06	(2)
Income from investment operations:
Net investment income		$			0.06	*
Net realized and unrealized gain on investments		$			0.20
Total from investment operations		$			0.26
Less distributions from:
Net investment income		$			0.04
Tax return of capital		$			0.10
Total distributions		$			0.14
Net asset value, end of period		$			19.18
Market value, end of period		$			18.76
Total investment return at net asset value(3)		%			1.38
Total investment return at market value(4)		%			(5.50	)
Ratios and Supplemental Data:
Net assets, end of period (000’s)		$			433,595
Ratios to average net assets:
Gross expenses prior to expense reimbursement(5)		%			1.23
Net expenses after expense reimbursement(5)		%			1.18
Net investment income(5)		%			0.88
Portfolio turnover rate		%			21

⁽¹⁾ Commencement of operations.

⁽²⁾ Net asset value at beginning of period reflects the deduction of the sales load of $0.90 per share and offering costs of $0.04 per share paid by the shareholder from the $20.00 offering price.

⁽³⁾ Total investment return at net asset value has been calculated assuming a purchase at net asset value at the beginning of each period and a sale at net asset value at the end of each period and assumes reinvestment of dividends and capital gain distributions, if any, in accordance with the provisions of the dividend reinvestment plan. Total investment return at net asset value is not annualized for periods less than one year.

⁽⁴⁾ Total investment return at market value measures the change in the market value of your investment assuming reinvestment of dividends and capital gain distributions, if any, in accordance with the provisions of the Fund’s dividend reinvestment plan. Total investment return at market value is not annualized for periods less than one year.

⁽⁵⁾ Annualized for periods less than one year.

* Per share data calculated using average number of shares outstanding throughout the period.

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NOTE 1 — ORGANIZATION

ING Risk Managed Natural Resources Fund (the “Fund”) is a non-diversified, closed-end management investment company registered under the Investment Company Act of 1940, as amended (the “1940 Act”). The Fund is organized as a Delaware statutory trust. The investment objective for the Fund is total return through a combination of current income, capital gains and capital appreciation. The Fund seeks to achieve its investment objective by investing at least 80% of its managed assets in the equity securities of, or derivatives linked to the equity securities of Natural Resources Companies. Additionally, the Fund employs an integrated options “collar” strategy to seek to partially reduce the exposure of the Fund to declines in the value of the energy and natural resources securities in its portfolio and to help the Fund achieve its investment objective by seeking to generate capital gains in declining markets from the purchase of put options and premiums from writing call options. Put options will be financed by a portion of the premiums received by the Fund from the sale of call options.

NOTE 2 — SIGNIFICANT ACCOUNTING POLICIES

The following significant accounting policies are consistently followed by the Fund in the preparation of its financial statements, and such policies are in conformity with U.S. generally accepted accounting principles for investment companies.

A.	Security Valuation. Investments in equity securities traded on a national securities exchange are valued at the last reported sale price. Securities reported by NASDAQ are valued at the NASDAQ official closing prices. Securities traded on an exchange or NASDAQ for which there has been no sale and equity securities traded in the over-the-counter-market are valued at the mean between the last reported bid and ask prices. All investments quoted in foreign currencies will be valued daily in U.S. dollars on the basis of the foreign currency exchange rates prevailing at that time. Debt securities are valued at prices obtained from independent services or from one or more dealers making markets in the securities and may be adjusted based on the Fund’s valuation procedures. U.S. government obligations are valued by using market quotations or independent pricing services which use prices provided by market-makers or estimates of market values obtained from yield data relating to instruments or securities with similar characteristics.
	Securities and assets for which market quotations are not readily available (which may include certain restricted securities which are subject to limitations as to their sale) are valued at their fair values as determined in good faith by or under the supervision of the Fund’s Board of Trustees (“Board”), in accordance with methods that are specifically authorized by the Board. Securities traded on exchanges, including foreign exchanges, which close earlier than the time that the Fund calculates its net asset value (“NAV”) may also be valued at their fair values as determined in good faith by or under the supervision of the Fund’s Board, in accordance with methods that are specifically authorized by the Board. The value of a foreign security traded on an exchange outside the United States is generally based on its price on the principal foreign exchange where it trades as of the time the Fund determines its NAV or if the foreign exchange closes prior to the time the Fund determines its NAV, the most recent closing price of the foreign security on its principal exchange. Trading in certain non-U.S. securities may not take place on all days on which the New York Stock Exchange (“NYSE”) is open. Further, trading takes place in various foreign markets on days on which the NYSE is not open. Consequently, the calculation of the Fund’s NAV may not take place contemporaneously with the determination of the prices of securities held by the Fund in foreign securities markets. Further, the value of the Fund’s assets may be significantly affected by foreign trading on days when a shareholder cannot purchase or redeem shares of the Fund. In calculating the Fund’s NAV, foreign securities denominated in foreign currency are converted to U.S. dollar equivalents. If an event occurs after the time at which the market for foreign securities held by the Fund closes but before the time that the Fund’s NAV is calculated, such event may cause the closing price on the foreign exchange to not represent a readily available reliable market value quotation for such securities at the time the Fund determines its NAV. In such a case, the Fund will use the fair value of such securities as determined under the Fund’s valuation procedures. Events after the close of trading on a foreign market that could require the Fund to fair value some or

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	all of its foreign securities include, among others, securities trading in the U.S. and other markets, corporate announcements, natural and other disasters, and political and other events. Among other elements of analysis in the determination of a security’s fair value, the Board has authorized the use of one or more independent research services to assist with such determinations. An independent research service may use statistical analyses and quantitative models to help determine fair value as of the time the Fund calculates its NAV. There can be no assurance that such models accurately reflect the behavior of the applicable markets or the effect of the behavior of such markets on the fair value of securities, or that such markets will continue to behave in a fashion that is consistent with such models. Unlike the closing price of a security on an exchange, fair value determinations employ elements of judgment. Consequently, the fair value assigned to a security may not represent the actual value that the Fund could obtain if it were to sell the security at the time of the close of the NYSE. Pursuant to procedures adopted by the Board, the Fund is not obligated to use the fair valuations suggested by any research service, and valuation recommendations provided by such research services may be overridden if other events have occurred or if other fair valuations are determined in good faith to be more accurate. Unless an event is such that it causes the Fund to determine that the closing prices for one or more securities do not represent readily available reliable market value quotations at the time the Fund determines its NAV, events that occur between the time of the close of the foreign market on which they are traded and the close of regular trading on the NYSE will not be reflected in the Fund’s NAV. Investments in securities maturing in 60 days or less are valued at amortized cost, which, when combined with accrued interest, approximates market value.
	Options that are traded over-the-counter will be valued using one of three methods: (1) dealer quotes, (2) industry models with objective inputs, or (3) by using a benchmark arrived at by comparing prior-day dealer quotes with the corresponding change in the underlying security. Exchange traded options will be valued using the last reported sale. If no last sale is reported, exchange traded options will be valued using an industry accepted model such as “Black Scholes.” Options on currencies purchased by the Fund are valued using industry models with objective inputs at their last bid price in the case of listed options or at the average of the last bid prices obtained from dealers in the case of over-the-counter options.
B.	Security Transactions and Revenue Recognition. Security transactions are recorded on the trade date. Realized gains or losses on sales of investments are calculated on the identified cost basis. Interest income is recorded on the accrual basis. Premium amortization and discount accretion are determined using the effective yield method. Dividend income is recorded on the ex-dividend date, or in the case of some foreign dividends, when the information becomes available to the Fund.
C.	Foreign Currency Translation. The books and records of the Fund are maintained in U.S. dollars. Any foreign currency amounts are translated into U.S. dollars on the following basis:

	(1)	Market value of investment securities, other assets and liabilities — at the exchange rates prevailing at the end of the day.
	(2)	Purchases and sales of investment securities, income and expenses — at the rates of exchange prevailing on the respective dates of such transactions.

Although the net assets and the market values are presented at the foreign exchange rates at the end of the day, the Fund does not isolate the portion of the results of operations resulting from changes in foreign exchange rates on investments from the fluctuations arising from changes in market prices of securities held. Such fluctuations are included with the net realized and unrealized gains or losses from investments. For securities, which are subject to foreign withholding tax upon disposition, liabilities are recorded on the Statement of Assets and Liabilities for the estimated tax withholding based on the securities current market value. Upon disposition, realized gains or losses on such securities are recorded net of foreign withholding tax. Reported net realized foreign exchange gains or losses arise from sales of

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	foreign currencies, currency gains or losses realized between the trade and settlement dates on securities transactions, the difference between the amounts of dividends, interest, and foreign withholding taxes recorded on the Fund’s books and the U.S. dollar equivalent of the amounts actually received or paid. Net unrealized foreign exchange gains and losses arise from changes in the value of assets and liabilities other than investments in securities at period end, resulting from changes in the exchange rate. Foreign security and currency transactions may involve certain considerations and risks not typically associated with investing in U.S. companies and U.S. government securities. These risks include, but are not limited to, revaluation of currencies and future adverse political and economic developments which could cause securities and their markets to be less liquid and prices more volatile than those of comparable U.S. companies and U.S. government securities.
D.	Forward Foreign Currency Contracts. The Fund may enter into forward foreign currency contracts primarily to hedge against foreign currency exchange rate risks on their non-U.S. dollar denominated investment securities. When entering into a currency forward contract, the Fund agrees to receive or deliver a fixed quantity of foreign currency for an agreed-upon price on an agreed future date. These contracts are valued daily and the Fund’s net equity therein, representing unrealized gain or loss on the contracts as measured by the difference between the forward foreign exchange rates at the dates of entry into the contracts and the forward rates at the reporting date, is included in the statement of assets and liabilities. Realized and unrealized gains and losses on forward foreign currency contracts are included on the Statement of Operations. These instruments involve market and/or credit risk in excess of the amount recognized in the statement of assets and liabilities. Risks arise from the possible inability of counterparties to meet in terms of their contracts and from movement in currency and securities values and interest rates.
E.	Distributions to Shareholders. Dividends from net investment income and net realized gains, if any, are declared and paid quarterly by the Fund. Distributions are determined annually in accordance with federal tax principles, which may differ from U.S. generally accepted accounting principles for investment companies. The Fund may make distributions on a more frequent basis to comply with the distribution requirements of the Internal Revenue Code. Distributions are recorded on the ex-dividend date.
	The Fund intends to make regular quarterly distributions based on the past and projected performance of the Fund. The tax treatment and characterization of the Fund’s distributions may vary significantly from time to time depending on whether the Fund has gains or losses on the call options written on its portfolio versus gains or losses on the equity securities in the portfolio. The Fund’s distributions will normally reflect past and projected net investment income, and may include income from dividends and interest, capital gains and/or a return of capital. The final composition of the tax characteristics of the distributions cannot by determined with certainty until after the end of the year, and will be reported to shareholders at that time. The amount of quarterly distributions will vary, depending on a number of factors. As portfolio and market conditions change, the rate of dividends on the common shares will change. There can be no assurance that the Fund will be able to declare a dividend in each period.
F.	Federal Income Taxes. It is the policy of the Fund to comply with subchapter M of the Internal Revenue Code and related excise tax provisions applicable to regulated investment companies and to distribute substantially all of its net investment income and any net realized capital gains to its shareholders. Therefore, no federal income tax provision is required. No capital gain distributions shall be made until any capital loss carryforwards have been fully utilized or expired.
G.	Use of Estimates. The preparation of financial statements in conformity with U.S. generally accepted accounting principles requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements and the reported amounts of increases and decreases in net assets from operations during

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	the reporting period. Actual results could differ from those estimates.
H.	Securities Lending. Under an agreement with The Bank of New York (“BNY”) the Fund has the option to temporarily loan up to 30% of its managed assets to brokers, dealers or other financial institutions in exchange for a negotiated lender’s fee. The borrower is required to fully collateralize the loans with cash or U.S. government securities. Generally, in the event of counterparty default, the Fund has the right to use collateral to offset losses incurred. There would be potential loss to the Fund in the event the Fund is delayed or prevented from exercising its right to dispose of the collateral. The Fund bears the risk of loss with respect to the investment of collateral. Engaging in securities lending could have a leveraging effect, which may intensify the credit, market and other risks associated with investing in the Fund.
I.	Offering Costs and Organization Expenses. Costs incurred with the offering of common shares were recorded as a reduction of capital paid in excess of par applicable to common shares. Organization expenses are expensed as incurred.
J.	Options Contracts. The Fund may purchase put and call options and may write (sell) put options and covered call options. The premium received by the Fund upon the writing of a put or call option is included in the Statement of Assets and Liabilities as a liability which is subsequently marked-to-market until it is exercised or closed, or it expires. The Fund will realize a gain or loss upon the expiration or closing of the option contract. When an option is exercised, the proceeds on sales of the underlying security for a written call option or purchased put option or the purchase cost of the security for a written put option or a purchased call option is adjusted by the amount of premium received or paid. The risk in writing a call option is that the Fund gives up the opportunity for profit if the market price of the security increases and the option is exercised. The risk in writing a put option is that the Fund may incur a loss if the market price of the security decreases and the option is exercised. The risk in buying an option is that the Fund pays a premium whether or not the option is exercised. Risks may also arise from an illiquid secondary market or from the inability of counterparties to meet the terms of the contract.
	Under normal market conditions, the Fund will seek to manage risk by employing an integrated options “collar” strategy. The Fund’s collar strategy will include purchasing put options and writing call options on Resource Indices and/or ETFs, correlated with the Fund’s portfolio, or securities held in the Fund’s portfolio. Under normal market conditions, the Fund will generally purchase put options approximately 5% “out-of-the-money,” usually on a three-month basis and for an amount approximating 100% of the value of the Fund’s underlying assets. The Fund will usually write call options “at-the-money” or “near-to-the-money,” usually on a one-month basis and for an amount equal to 50-100% of the value of the Fund’s underlying assets. The Fund’s collar strategy seeks to partially reduce the exposure of the Fund to declines in the value of the securities of Natural Resources Companies in its portfolio, while simultaneously generating capital gains from the purchase of put options and premiums from writing call options to help the Fund achieve its total return investment objective. Put options will be financed by a portion of the premiums received by the Fund from the sale of call options.
K.	Repurchase Agreements. The Fund may invest in repurchase agreements only with government securities dealers recognized by the Board of Governors of the Federal Reserve System. Under such agreements, the seller of the security agrees to repurchase it at a mutually agreed upon time and price. The resale price is in excess of the purchase price and reflects an agreed upon interest rate for the period of time the agreement is outstanding. The period of the repurchase agreements is usually short, from overnight to one week, while the underlying securities generally have longer maturities. The Fund will receive as collateral securities acceptable to it whose market value is equal to at least 100% of the carrying amount of the repurchase agreements, plus accrued interest, being invested by the Fund. The underlying collateral is valued daily on a mark to market basis to assure that the value, including accrued interest is at least equal to the repurchase price. There would be potential loss to the Fund in the

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	event the Fund is delayed or prevented from exercising its right to dispose of the collateral, and it might incur disposition costs in liquidating the collateral.

NOTE 3 — INVESTMENT MANAGEMENT AND ADMINISTRATIVE FEES

ING Investments, LLC (“ING Investments” or the “Investment Adviser”), an Arizona limited liability company, is the Investment Adviser of the Fund. The Fund pays the Investment Adviser for its services under the investment management agreement (“Management Agreement”), a fee, payable monthly, based on an annual rate of 1.00% of the Fund’s average daily managed assets. For the purposes of the Management Agreement, managed assets are defined as the Fund’s average daily gross asset value, minus the sum of the Fund’s accrued and unpaid dividends on any outstanding preferred shares and accrued liabilities (other than liabilities for the principal amount of any borrowings incurred, commercial paper or notes issued by the Fund and the liquidation preference of any outstanding preferred shares). As of February 28, 2007, there were no preferred shares outstanding.

The Investment Adviser entered into a sub-advisory agreement (“Sub-Advisory Agreement”) with ING Investment Management Co. (“ING IM”). Subject to policies as the Board or the Investment Adviser might determine, ING IM manages the Fund’s assets in accordance with the Fund’s investment objectives, policies and limitations.

Effective November 1, 2006, all ING funds sub-advised by ING IM are permitted to invest end-of-day cash balances into affiliated ING Money Market Funds, including ING Institutional Prime Money Market Fund. Investment management fees paid by the Fund will be reduced by an amount equal to the management fees paid indirectly to the ING Institutional Prime Money Market Fund with respect to assets invested by the Fund.

ING Funds Services, LLC (the “Administrator”) serves as Administrator to the Fund. The Fund pays the Administrator for its services a fee based on an annual rate of 0.10% of the Fund’s average daily managed assets. The Investment Adviser, ING IM, and the Administrator are indirect, wholly-owned subsidiaries of ING Groep N.V. (“ING Groep”). ING Groep is one of the largest financial services organizations in the world, and offers an array of banking, insurance and asset management services to both individuals and institutional investors.

NOTE 4 — OTHER TRANSACTIONS WITH AFFILIATED AND RELATED PARTIES

At February 28, 2007, the Fund had the following amounts recorded in payable to affiliates on the accompanying Statement of Assets and Liabilities:

Accrued
Investment		Accrued
Management		Administrative
Fees		Fees		Total
$263,050		$33,305		$296,355

The Fund has adopted a Retirement Policy (“Policy”) covering all Independent Trustees of the Fund who will have served as an Independent Trustee for at least five years at the time of retirement. Benefits under this Policy are based on an annual rate as defined in the Policy agreement and are recorded as trustee fees in the financial statements.

NOTE 5 — PURCHASES AND SALES OF INVESTMENT SECURITIES

The cost of purchases and proceeds from sales of investments for the period ended February 28, 2007, excluding short-term securities, were $496,834,071 and $88,997,649, respectively.

NOTE 6 — CALL OPTIONS WRITTEN

Written option activity for the Fund for the period ended February 28, 2007 was as follows:

		Number of
		Contracts				Premium
Balance at 2/28/2006			—			$	—
Options written			2,235,800				30,641,816
Options expired			(409,800	)			(6,773,625	)
Options exercised			(1,251,500	)			(17,506,247	)
Balance at 2/28/2007			574,500			$	6,361,944

NOTE 7 — CONCENTRATION OF INVESTMENT RISKS

Foreign Securities and Emerging Markets. The Fund makes significant investments in foreign securities and may invest up to 20% of its managed assets in securities issued by companies located in countries with emerging markets. Investments in foreign securities may entail risks not present in domestic investments. Since investments in securities are denominated in foreign currencies, changes in the relationship of these foreign currencies to the U.S. dollar can significantly affect the value of the investments and earnings of the Fund. Foreign investments may also subject the Fund to foreign government exchange restrictions, expropriation, taxation or other political, social or economic

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developments, as well as from movements in currency, security value and interest rate, all of which could affect the market and/or credit risk of the investments. The risks of investing in foreign securities can be intensified in the case of investments in issuers located in countries with emerging markets.

Leverage. Although the Fund has no current intention to do so, the Fund is authorized to utilize leverage through the issuance of preferred shares and/or borrowings, including the issuance of debt securities. The Fund also may enter into a working capital facility to facilitate its collar strategy. In the event that the Fund determines in the future to utilize investment leverage, there can be no assurance that such a leveraging strategy will be successful during any period in which it is employed.

Non-Diversified and Natural Resources Companies. The Fund may be subject to large price volatility due to non-diversification and concentration in Natural Resources Companies. Securities of such companies may be subject to broad price fluctuations, reflecting volatility of energy and basic materials’ prices and possible instability of supply of various natural resources. Because many Natural Resources Companies have significant operations in many countries worldwide, the Fund’s portfolio will be more exposed than a more diversified portfolio to unstable political, social and economic conditions, including expropriation and disruption of licenses or operations. This means that the Fund’s portfolio of Natural Resources Companies may be more exposed to price volatility, liquidity and other risks that accompany an investment in equities of foreign companies than portfolios of international equities generally.

NOTE 8 — CAPITAL SHARES

Transaction in capital shares and dollars were as follows:

		Class A
		October 24,
		2006(1) to
		February 28,
		2007
Number of Shares
Shares sold			22,600,000
Dividends reinvested			4,972
Net increase in shares outstanding			22,604,972
$
Shares sold(2)			430,756,000
Dividends reinvested			94,784
Net increase			430,850,784

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(1)	Commencement of operations.
(2)	Proceeds from sales of shares net of sales load paid of $20,340,000 and offering costs of $904,000.

NOTE 9 — ILLIQUID SECURITIES

Pursuant to guidelines adopted by the Fund’s Board, the following securities have been deemed to be illiquid. The Fund may invest up to 15% of its net assets, at market value, in illiquid securities at time of purchase.

						Initial												Percent
		Share				Acquisition												of Net
Security		Amount				Date				Cost				Value				Assets
Cano Petroleum, Inc.			262,500				10/27/06			$	1,372,237			$	1,207,500				0.3	%
PetroHawk Energy Corp.			43,800				10/27/06				502,106				524,286				0.1	%
										$	1,874,343			$	1,731,786				0.4	%

NOTE 10 — SECURITIES LENDING

Under an agreement with BNY, the Fund can lend its securities to approved brokers, dealers and other financial institutions. Loans are collateralized by cash and U.S. government securities. The collateral must be in an amount equal to at least 105% of the market value of non-U.S. securities loaned and 102% of the market value of U.S. securities loaned. The cash collateral received is invested in approved investments as defined in the Securities Lending Agreement with BNY (the “Agreement”). The securities purchased with cash collateral received are reflected in the Portfolio of Investments. Generally, in the event of counterparty default, the Fund has the right to use the collateral to offset losses incurred. The Agreement contains certain guarantees by BNY in the event of counterparty default and/or a borrower’s failure to return a loaned security; however there would be a

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potential loss to the Fund in the event the Fund is delayed or prevented from exercising their right to dispose of the collateral. The Fund bears the risk of loss with respect to the investment of collateral. Engaging in securities lending could have a leveraging effect, which may intensify the credit, market and other risks associated with investing in the Fund. At February 28, 2007, the Fund did not have any securities on loan.

NOTE 11 — FEDERAL INCOME TAXES

The amount of distributions from net investment income and net realized capital gains are determined in accordance with federal income tax regulations, which may differ from U.S. generally accepted accounting principles for investment companies. These book/tax differences may be either temporary or permanent. Permanent differences are reclassified within the capital accounts based on their federal tax-basis treatment; temporary differences are not reclassified. Key differences include the treatment of short-term capital gains, foreign currency transactions, and wash sale deferrals. Distributions in excess of net investment income and/or net realized capital gains for tax purposes are reported as distributions of paid-in capital.

The following permanent tax differences have been reclassified as of the Fund’s tax year ended December 31, 2006:

								Accumulated
Paid-in				Undistributed Net				Net Realized
Capital				Investment Income				Gains/ (Losses)
	$(36,303)			$	50,684			$	(14,381	)

Dividends paid by the Fund from net investment income and distributions of net realized short-term capital gains are, for federal income tax purposes, taxable as ordinary income to shareholders.

The tax composition of dividends and distributions to shareholders was as follows:

Tax Year Ended December 31, 2006
Ordinary		Return of
Income		Capital
$878,010		$	2,331,900

The tax-basis components of distributable earnings and the expiration dates of the capital loss carryforwards which may be used to offset future realized capital gains for federal income tax purposes as of the tax year ended December 31, 2006 were:

Unrealized		Post-October
Appreciation/		Capital Losses
(Depreciation)		Deferred
$14,170,996		$	(16,510,393	)

NOTE 12 — OTHER ACCOUNTING PRONOUNCEMENTS

In June 2006, the Financial Accounting Standards Board (“FASB”) issued FASB Interpretation No. 48 (“FIN 48”), “Accounting for Uncertainty in Income Taxes.” This standard defines the threshold for recognizing the benefits of tax-return positions in the financial statements as “more-likely-than-not” to be sustained upon challenge by the taxing authority and requires measurement of a tax position meeting the more-likely-than-not criterion, based on the largest benefit that is more than 50 percent likely to be realized. FIN 48 is effective for fiscal years beginning after December 15, 2006, with early application permitted if no interim financial statements have been issued. However, acknowledging the unique issues that FIN 48 presents for investment companies that calculate NAVs, the U.S. Securities and Exchange Commission (the “SEC”) has indicated that they would not object if a fund implements FIN 48 in its NAV calculation as late as its last NAV calculation in the first required financial statement reporting period for its fiscal year beginning after December 15, 2006. For the February year-end closed-end funds, this would be no later than their August 31, 2007 NAV and the effects of FIN 48 would be reflected in the funds’ semi-annual financial statements contained in their Form N-CSR filing. At adoption, companies must adjust their financial statements to reflect only those tax positions that are more likely-than-not to be sustained as of the adoption date. Management of the Fund has assessed the impact of adopting FIN 48 and currently does not believe that there will be a material impact to the Fund.

On September 15, 2006, the FASB issued Statement of Financial Accounting Standards No. 157 (“SFAS No. 157”), “Fair Value Measurements.” The new accounting statement defines fair value, establishes a framework for measuring fair value in generally accepted accounting principles (“GAAP”), and expands disclosures about fair value measurements. SFAS No. 157 defines fair value as the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date (an exit price). SFAS No. 157 also stipulates that, as a market-

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based measurement, fair value measurement should be determined based on the assumptions that market participants would use in pricing the asset or liability, and establishes a fair value hierarchy that distinguishes between (a) market participant assumptions developed based on market data obtained from sources independent of the reporting entity (observable inputs) and (b) the reporting entity’s own assumptions about market participant assumptions developed based on the best information available in the circumstances (unobservable inputs). SFAS No. 157 is effective for financial statements issued for fiscal years beginning after November 15, 2007. As of February 28, 2007, management of the Fund is currently assessing the impact, if any, that will result from adopting SFAS No. 157.

NOTE 13 — INFORMATION REGARDING TRADING OF ING’S U.S. MUTUAL FUNDS

In 2004, ING Investments reported to the Boards of Directors/ Trustees (the “Boards”) of the ING Funds that, like many U.S. financial services companies, ING Investments and certain of its U.S. affiliates have received informal and formal requests for information since September 2003 from various governmental and self-regulatory agencies in connection with investigations related to mutual funds and variable insurance products. ING Investments has advised the Boards that it and its affiliates have cooperated fully with each request.

In addition to responding to regulatory and governmental requests, ING Investments reported that management of U.S. affiliates of ING Groep, including ING Investments (collectively, “ING”), on their own initiative, have conducted, through independent special counsel and a national accounting firm, an extensive internal review of trading in ING insurance, retirement, and mutual fund products. The goal of this review was to identify any instances of inappropriate trading in those products by third parties or by ING investment professionals and other ING personnel. ING’s internal review related to mutual fund trading is now substantially completed. ING has reported that, of the millions of customer relationships that ING maintains, the internal review identified several isolated arrangements allowing third parties to engage in frequent trading of mutual funds within ING’s variable insurance and mutual fund products, and identified other circumstances where frequent trading occurred, despite measures taken by ING intended to combat market timing. ING further reported that each of these arrangements has been terminated and fully disclosed to regulators. The results of the internal review were also reported to the independent members of the Boards.

ING Investments has advised the Boards that most of the identified arrangements were initiated prior to ING’s acquisition of the businesses in question in the U.S. ING Investments further reported that the companies in question did not receive special benefits in return for any of these arrangements, which have all been terminated.

Based on the internal review, ING Investments has advised the Boards that the identified arrangements do not represent a systemic problem in any of the companies that were involved.

In September 2005, ING Funds Distributor, LLC (“IFD”), the distributor of certain ING Funds, settled an administrative proceeding with the NASD regarding three arrangements, dating from 1995, 1996 and 1998, under which the administrator to the then-Pilgrim Funds, which subsequently became part of the ING Funds, entered into formal and informal arrangements that permitted frequent trading. Under the terms of the Letter of Acceptance, Waiver and Consent (“AWC”) with the NASD, under which IFD neither admitted nor denied the allegations or findings, IFD consented to the following sanctions: (i) a censure; (ii) a fine of $1.5 million; (iii) restitution of approximately $1.44 million to certain ING Funds for losses attributable to excessive trading described in the AWC; and (iv) agreement to make certification to NASD regarding the review and establishment of certain procedures.

In addition to the arrangements discussed above, in 2004 ING Investments reported to the Boards that, at that time, these instances include the following, in addition to the arrangements subject to the AWC discussed above:

•	Aeltus Investment Management, Inc. (a predecessor entity to ING IM) identified two investment professionals who engaged in extensive frequent trading in certain ING Funds. One was subsequently terminated for cause and incurred substantial financial penalties in connection with this conduct and the second has been disciplined.
•	ReliaStar Life Insurance Company (“ReliaStar”) entered into agreements seven years ago

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	permitting the owner of policies issued by the insurer to engage in frequent trading and to submit orders until 4pm Central Time. In 2001 ReliaStar also entered into a selling agreement with a broker- dealer that engaged in frequent trading. Employees of ING affiliates were terminated and/or disciplined in connection with these matters.
•	In 1998, Golden American Life Insurance Company entered into arrangements permitting a broker-dealer to frequently trade up to certain specific limits in a fund available in an ING variable annuity product. No employee responsible for this arrangement remains at the company.

For additional information regarding these matters, you may consult the Form 8-K and Form 8-K/A for each of four life insurance companies, ING USA Annuity and Life Insurance Company, ING Life Insurance and Annuity Company, ING Insurance Company of America, and ReliaStar Life Insurance Company of New York, each filed with the SEC on October 29, 2004 and September 8, 2004. These Forms 8-K and Forms 8-K/A can be accessed through the SEC’s website at http://www.sec.gov. Despite the extensive internal review conducted through independent special counsel and a national accounting firm, there can be no assurance that the instances of inappropriate trading reported to the Boards are the only instances of such trading respecting the ING Funds.

ING Investments reported to the Boards that ING is committed to conducting its business with the highest standards of ethical conduct with zero tolerance for noncompliance. Accordingly, ING Investments advised the Boards that ING management was disappointed that its voluntary internal review identified these situations. Viewed in the context of the breadth and magnitude of its U.S. business as a whole, ING management does not believe that ING’s acquired companies had systemic ethical or compliance issues in these areas. Nonetheless, ING Investments reported that given ING’s refusal to tolerate any lapses, it has taken the steps noted below, and will continue to seek opportunities to further strengthen the internal controls of its affiliates.

•	ING has agreed with the ING Funds to indemnify and hold harmless the ING Funds from all damages resulting from wrongful conduct by ING or its employees or from ING’s internal investigation, any investigations conducted by any governmental or self-regulatory agencies, litigation or other formal proceedings, including any proceedings by the SEC. ING Investments reported to the Boards that ING management believes that the total amount of any indemnification obligations will not be material to ING or its U.S. business.
•	ING updated its Code of Conduct for employees reinforcing its employees’ obligation to conduct personal trading activity consistent with the law, disclosed limits, and other requirements.
•	The ING Funds, upon a recommendation from ING, updated their respective Codes of Ethics applicable to investment professionals with ING entities and certain other fund personnel, requiring such personnel to pre-clear any purchases or sales of ING Funds that are not systematic in nature (i.e., dividend reinvestment), and imposing minimum holding periods for shares of ING Funds.
•	ING instituted excessive trading policies for all customers in its variable insurance and retirement products and for shareholders of the ING Funds sold to the public through financial intermediaries. ING does not make exceptions to these policies.
•	ING reorganized and expanded its U.S. Compliance Department, and created an Enterprise Compliance team to enhance controls and consistency in regulatory compliance.

Other Regulatory Matters

The New York Attorney General (the “NYAG”) and other federal and state regulators are also conducting broad inquiries and investigations involving the insurance industry. These initiatives currently focus on, among other things, compensation and other sales incentives; potential conflicts of interest; potential anti-competitive activity; reinsurance; marketing practices (including suitability); specific product types (including group annuities and indexed annuities); fund selection for investment products and brokerage sales; and disclosure. It is likely that the scope of these industry investigations will further broaden before they conclude. ING has received formal and informal requests in connection with such investigations, and is cooperating fully with each request. In connection with one such investigation, affiliates of ING Investments were named in a petition for relief and cease and desist order filed by the New Hampshire Bureau of Securities Regulation (the “NH Bureau”) concerning their administration of the New

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Hampshire state employees deferred compensation plan.

On October 10, 2006, an affiliate of ING Investments entered into an assurance of discontinuance with the NYAG (the “NYAG Agreement”) regarding the endorsement of its products by the New York State United Teachers Union Member Benefits Trust (“NYSUT”) and the sale of their products to NYSUT members. Under the terms of the NYAG Agreement, the affiliate of ING Investments, without admitting or denying the NYAG’s findings, will distribute $30 million to NYSUT members, and/or former NYSUT members, who participated in the NYSUT-endorsed products at any point between January 1, 2001 and June 30, 2006. The affiliate also agreed with the NYAG’s office to develop a one-page disclosure that will further improve transparency and disclosure regarding retirement product fees (the “One-Page Disclosure”). Pursuant to the terms of the NYAG Agreement, the affiliate has agreed for a five year period to provide its retirement product customers with the One-Page Disclosure.

In addition, on the same date, these affiliates of ING Investments entered into a consent agreement with the NH Bureau (the “NH Agreement”) to resolve this petition for relief and cease and desist order. Under the terms of the NH Agreement, these affiliates of ING Investments, without admitting or denying the NH Bureau’s claims, have agreed to pay $3 million to resolve the matter, and for a five year period to provide their retirement product customers with the One-Page Disclosure described above.

Other federal and state regulators could initiate similar actions in this or other areas of ING’s businesses.

These regulatory initiatives may result in new legislation and regulation that could significantly affect the financial services industry, including businesses in which ING is engaged.

In light of these and other developments, ING continuously reviews whether modifications to its business practices are appropriate.

At this time, in light of the current regulatory factors, ING U.S. is actively engaged in reviewing whether any modifications in our practices are appropriate for the future.

There can be no assurance that these matters, or the adverse publicity associated with them, will not result in increased fund redemptions, reduced sale of fund shares, or other adverse consequences to ING Funds.

NOTE 14 — SUBSEQUENT EVENTS

Dividends: Subsequent to February 28, 2007, the Fund declared a quarterly dividend of:

Per Share		Declaration		Payable		Record
Amount		Date		Date		Date
$0.425		3/23/2007		4/16/2007		4/4/2007

The Fund estimates that distributions for the tax year commencing on January 1, 2007, and including the distributions listed above, will be comprised of approximately 5% net investment income. The remaining portion of the Fund’s monthly distributions is estimated to come from the Fund’s covered-call option strategy, which for tax purposes, may be treated as a combination of long-term and short-term capital gains, and/or a return of capital. The tax character of the Fund’s covered-call option strategy is largely determined by movements in the underlying equity portfolio. Based on the current realized appreciation in the Fund’s underlying equity portfolio, the Fund estimates that the remaining approximately 95% of the distributions would be considered short-term capital gain.

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Shares								Value
COMMON STOCK: 97.7%
						Chemicals: 7.1%
	35,200					Air Products & Chemicals, Inc.		$	2,633,664
	9,450					Ashland, Inc.			619,731
	146,550					Dow Chemical Co.			6,418,890
	13,350					Eastman Chemical Co.			789,252
	28,800					Ecolab, Inc.			1,218,240
	141,050					EI DuPont de Nemours & Co.			7,158,288
	18,650			@		Hercules, Inc.			375,984
	13,050					International Flavors & Fragrances, Inc.			610,740
	83,350					Monsanto Co.			4,391,712
	26,650					PPG Industries, Inc.			1,765,563
	44,700					Praxair, Inc.			2,757,543
	23,100					Rohm & Haas Co.			1,221,066
	22,100					Sigma-Aldrich Corp.			906,100
									30,866,773
						Coal: 1.4%
	47,300					Arch Coal, Inc.			1,472,922
	71,600					Consol Energy, Inc.			2,553,972
	50,100					Peabody Energy Corp.			2,024,040
									6,050,934
						Electric: 0.5%
	36,700			@		Mirant Corp.			1,367,442
	10,700			@		NRG Energy, Inc.			708,768
									2,076,210
						Energy — Alternate Sources: 0.3%
	127,400			@		Evergreen Energy, Inc.			1,000,090
	29,939			@		US BioEnergy Corp.			389,806
									1,389,896
						Engineering & Construction: 0.3%
	25,100			@		McDermott International, Inc.			1,209,820
									1,209,820
						Forest Products & Paper: 1.8%
	72,600					International Paper Co.			2,614,326
	29,350					MeadWestvaco Corp.			893,708
	17,400					Temple-Inland, Inc.			1,040,520
	37,750					Weyerhaeuser Co.			3,241,593
									7,790,147
						Investment Companies: 0.1%
	86,800			@,@@		Energy XXI Acquisition Corp. Bermuda Ltd.			429,660
									429,660
						Iron/ Steel: 2.3%
	16,400					Allegheny Technologies, Inc.			1,680,180
	18,100			@@		Arcelor Mittal			920,566
	11,300					Cleveland-Cliffs, Inc.			637,320
	59,050					Nucor Corp.			3,594,374
	33,700					United States Steel Corp.			2,986,494
									9,818,934
						Metal Fabricate/ Hardware: 0.1%
	9,300			@@,#		TMK OAO			297,600
									297,600
						Mining: 9.3%
	8,100			@@		Aber Diamond Corp.			289,656
	16,100			@@		Agnico-Eagle Mines Ltd.			633,213
	26,000			@@		Alcan, Inc.			1,351,480
	132,950					Alcoa, Inc.			4,441,860
	27,200			@,@@		Banro Corp.			340,272
	14,500			@@		BHP Billiton Ltd.			623,790
	34,400			@@		Cameco Corp.			1,272,059
	38,100			@@		Cia Vale do Rio Doce			1,299,972
	225,600			@,@@		Eldorado Gold Corp.			1,346,347
	18,000			@@		First Quantum Minerals Ltd.			1,045,742
	28,900			@,@@		First Uranium Corp.			251,294
	61,200					Freeport-McMoRan Copper & Gold, Inc.			3,513,492
	48,500			@,@@		Frontera Copper Corp.			186,602
	41,700			@@,S		Gold Fields Ltd.			729,034
	55,700			@@		GoldCorp, Inc.			1,493,317
	91,000			@		Hecla Mining Co.			700,700
	50,700			@,@@		Kinross Gold Corp.			713,856
	517,000			@,@@		Lihir Gold Ltd.			1,353,901
	11,300			@@		Lonmin PLC			691,033
	109,400			@,@@		MAG Silver Corp.			841,826
	75,700			@,@@		Major Drilling Group International			1,809,007
	69,050					Newmont Mining Corp.			3,112,084
	125,100			@,@@		Paladin Resources Ltd.			883,487
	30,200					Phelps Dodge Corp.			3,772,282
	53,200			@@,#		Polymetal			393,680
	56,900			@@		Randgold Resources Ltd.			1,303,010
	2,900			@@		Rio Tinto PLC			628,314
	194,000			@,@@		Shore Gold, Inc.			1,268,895
	25,800			@,@@		SXR Uranium One, Inc.			373,676
	17,400			@@		Teck Cominco Ltd.			1,225,308
	15,750					Vulcan Materials Co.			1,834,718
	38,800			@@		Yamana Gold, Inc.			568,420
									40,292,327
						Oil & Gas: 59.5%
	113,500					Anadarko Petroleum Corp.			4,566,105
	80,650					Apache Corp.			5,526,945
	47,100					Cabot Oil & Gas Corp.			3,182,076
	262,500			@,I		Cano Petroleum, Inc.			1,207,500
	120,250					Chesapeake Energy Corp.			3,666,423
	508,550					Chevron Corp.			34,891,616
	470,550					ConocoPhillips			30,783,381
	34,800			@		Delta Petroleum Corp.			696,000
	11,500			@		Denbury Resources, Inc.			331,660
	102,150					Devon Energy Corp.			6,712,277
	69,200					ENSCO International, Inc.			3,467,612
	80,300					EOG Resources, Inc.			5,439,522
	110,400			@		EXCO Resources, Inc.			1,923,168
	848,950					ExxonMobil Corp.			60,852,736
	39,841			@		GeoMet, Inc.			328,290
	25,300			@		Goodrich Petroleum Corp.			865,513
	155,200					Hess Corp.			8,233,360
	21,600			@,@@		InterOil Corp.			526,608
	174,200			@		Kodiak Oil & Gas Corp.			958,100
	3,100			@@		Lukoil ADR			244,159
	109,950					Marathon Oil Corp.			9,976,863
	59,900					Murphy Oil Corp.			3,104,018
	43,800					MV Oil Trust			994,260
	94,150			@,@@		Nabors Industries Ltd.			2,820,734
	88,400			@		Newfield Exploration Co.			3,820,648
	43,750					Noble Corp.			3,072,125
	283,150					Occidental Petroleum Corp.			13,075,859
	92,700			@		Parallel Petroleum Corp.			1,775,205
	43,800			@,I		PetroHawk Energy Corp.			524,286
	28,475			@@		Petroleo Brasileiro SA			2,574,140
	76,600			@		Petroquest Energy, Inc.			881,666
	68,700			@		Plains Exploration & Production Co.			3,134,781
	33,700			@		Quicksilver Resources, Inc.			1,299,809
	68,000					Rowan Cos., Inc.			2,082,840
	48,270			@@		Royal Dutch Shell PLC			3,138,033
	64,900			@		Southwestern Energy Co.			2,531,100
	40,600					Sunoco, Inc.			2,619,512
	13,000					Tesoro Petroleum Corp.			1,184,820
	28,500			@@		Total SA			1,918,620
	70,050			@		Transocean, Inc.			5,371,434

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Shares								Value
						Oil & Gas (continued)
	168,750					Valero Energy Corp.		$	9,728,438
	158,650					XTO Energy, Inc.			8,195,859
									258,228,101
						Oil & Gas Services: 11.0%
	145,600			@		Allis-Chalmers Energy, Inc.			2,389,296
	77,700					Baker Hughes, Inc.			5,059,047
	95,850					BJ Services Co.			2,567,822
	12,100			@		Cameron International Corp.			685,949
	23,700			@		Grant Prideco, Inc.			1,028,817
	230,600					Halliburton Co.			7,120,928
	31,000			@		Hercules Offshore, Inc.			825,530
	111,800			@		Key Energy Services, Inc.			1,844,700
	53,000			@		National Oilwell Varco, Inc.			3,690,920
	84,100			@		Particle Drilling Technologies, Inc.			336,400
	241,900					Schlumberger Ltd.			15,191,320
	38,750					Smith International, Inc.			1,588,750
	22,400			@		Superior Energy Services			686,560
	116,150			@		Weatherford International Ltd.			4,663,423
									47,679,462
						Packaging & Containers: 0.7%
	17,300					Ball Corp.			800,990
	16,800					Bemis Co.			556,584
	22,400			@		Pactiv Corp.			721,280
	13,050					Sealed Air Corp.			840,942
									2,919,796
						Pipelines: 3.3%
	224,850					El Paso Corp.			3,233,343
	32,600					Kinder Morgan, Inc.			3,447,776
	124,200					Spectra Energy Corp.			3,195,666
	10,500					Targa Resources Partners L.P.			253,050
	161,850					Williams Cos., Inc.			4,365,095
									14,494,930
						Total Common Stock (Cost $411,913,189)			423,544,590
POSITIONS IN PURCHASED OPTIONS: 2.4%
	8,900					Put Option OTC — (JPMorgan Chase) Basic Industries Select Sector Index, Strike 346.29, exp 03/16/07		$	979
	21,600					Put Option OTC — (JPMorgan Chase) Energy Select Sector Index, Strike 572.02, exp 03/16/07			272,160
	235,100					Put Option OTC — (JPMorgan Chase) Basic Industries Select Sector Index, Strike 348.88, exp 03/16/07			37,616
	564,200					Put Option OTC — (JPMorgan Chase) Energy Select Sector Index, Strike 581.58, exp 03/16/07			10,155,600
						Total Purchased Options (Cost $10,622,069)			10,466,355
						Total Long-Term Investments (Cost $422,535,258)			434,010,945
SHORT-TERM INVESTMENTS: 0.6%
						Repurchase Agreement: 0.6%
$	2,572,000			@@,S		Morgan Stanley Repurchase Agreement dated 02/28/07, 5.300%, due 03/01/07, $2,572,379 to be received upon repurchase (Collateralized by $7,490,000, Resolution Funding Corp., Discount Note Market Value plus accrued interest $2,624,726, due 04/15/30)		$	2,572,000
						Total Short-Term Investments (Cost $2,572,000)			2,572,000

				Total Investments in Securities (Cost $425,107,258)*			100.7	%		$	436,582,945
				Other Assets and Liabilities-Net			(0.7	)			(2,987,578	)
				Net Assets			100.0	%		$	433,595,367

@		Non-income producing security
@@		Foreign Issuer
ADR		American Depositary Receipt
#		Securities with purchases pursuant to Rule 144A, under the Securities Act of 1933 and may not be resold subject to that rule except to qualified institutional buyers. These securities have been determined to be liquid under the guidelines established by the Funds’ Board of Directors/Trustees.
S		Segregated securities for certain derivatives, when-issued or delayed delivery securities and forward currency exchange contracts.
I		Illiquid securities.
*		Cost for federal income tax purposes is $425,248,361. Net unrealized appreciation consists of:

Gross Unrealized Appreciation		$	18,182,554
Gross Unrealized Depreciation			(6,847,970	)
Net Unrealized Appreciation		$	11,334,584

At February 28, 2007 the following forward currency contracts were outstanding for the ING Risk Managed Natural Resources Fund:

										In								Unrealized
						Settlement				Exchange								Appreciation
Currency		Buy/Sell				Date				For				Value				(Depreciation)
										USD
Australia Dollars AUD 1,800,000			Sell				03/22/07				1,410,660			$	1,417,373			$	(6,713	)
Canada Dollars CAD 7,100,000			Sell				03/22/07				6,160,521				6,074,680				85,840
South Africa Rand ZAR 5,100,000			Sell				03/22/07				721,052				703,693				17,359
																		$	96,486

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ING Risk Managed Natural Resources Fund Written Options Outstanding on February 28, 2007:

																Premium
								Expiration				# of				Received Net
Description/Name of Issuer		Counterparty		Strike				Date				Contracts				of Commissions				Value
Call Option OTC — Energy Select Sector Index		JPMorgan Chase			579.01				03/16/07				419,800			$	5,493,334			$	(3,261,846	)
Call Option OTC — Basic Industries Select Sector Index		JPMorgan Chase			392.64				03/16/07				154,700				868,610				(309,400	)
																$	6,361,944			$	(3,571,246	)

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Supplemental Option Information (Unaudited)

Supplemental Call Option Statistics as of February 28, 2007
% of Total Net Assets against which calls written		70%
Average Days to Expiration		16 days
Average Call Moneyness* at time written		ATM
Premium received for calls		$6,361,944
Value of calls		$(3,571,246)
Supplemental Put Option Statistics as of February 28, 2007
% of Total Net Assets against which index puts purchased		100%
Average Days to Expiration		16 days
Average Index Put Moneyness* at time purchased		5% OTM
Premium paid for puts		$10,622,069
Value of puts		$10,466,355

*

“Moneyness” is the term used to describe the relationship between the price of the underlying asset and the option’s exercise or strike price. For example, a call (buy) option is considered “in-the-money” when the value of the underlying asset exceeds the strike price. Conversely, a put (sell) option is considered “in-the-money” when its strike price exceeds the value of the underlying asset. Options are characterized for the purpose of Moneyness as, “in-the-money” (“ITM”), “out-of-the-money” (“OTM”) or “at-the-money” (“ATM”), where the underlying asset value equals the strike price.

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Dividends paid during the year ended February 28, 2007 were as follows:

Fund Name		Type				Per Share Amount
ING Risk Managed Natural Resources Fund			NII			$	0.0388
			ROC			$	0.1032

NII — Net investment income

Above figures may differ from those cited elsewhere in this report due to differences in the calculation of income and gains under U.S. generally accepted accounting principles (book) purposes and Internal Revenue Service (tax) purposes.

Shareholders are strongly advised to consult their own tax advisers with respect to the tax consequences of their investments in the Fund. In January, shareholders, excluding corporate shareholders, receive an IRS 1099-DIV regarding the federal tax status of the dividends and distributions they received in the calendar year.

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The business and affairs of the Fund are managed under the direction of the Fund’s Board. A Trustee who is not an interested person of the Trust, as defined in the 1940 Act, is an independent trustee (“Independent Trustee”). The Trustees and Officers of the Fund are listed below. The Statement of Additional Information includes additional information about trustees of the Registrant and is available, without charge, upon request at 1-800-992-0180.

						Principal
		Position(s)		Term of Office		Occupation(s)
		held with		and Length of		during the Past
Name, Address and Age		Fund		Time Served(1)		Five Years
Independent Trustees:
John V. Boyer(2) 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 53		Trustee		September 2006 — Present		President and Chief Executive Officer, Franklin and Eleanor Roosevelt Institute (March 2006 — Present). Formerly, Executive Director, The Mark Twain House & Museum(3) (September 1989 — November 2005).
Patricia W. Chadwick(2) 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 58		Trustee		September 2006 — Present		Consultant and President of self- owned company, Ravengate Partners LLC (January 2000 — Present).
J. Michael Earley(4) 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 61		Trustee		September 2006 — Present		President, Chief Executive Officer and Director, Bankers Trust Company, N.A., Des Moines (June 1992 — Present).
R. Barbara Gitenstein(2) 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 59		Trustee		September 2006 — Present		President, College of New Jersey (January 1999 — Present).
Patrick W. Kenny(4) 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 64		Trustee		September 2006 — Present		President and Chief Executive Officer, International Insurance Society (June 2001 — Present).
Jock Patton(3) 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 61		Chairman and Trustee		September 2006 — Present		Private Investor (June 1997 — Present).
Sheryl K. Pressler(4) 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 56		Trustee		September 2006 — Present		Consultant (May 2001 — Present).
David W.C. Putnam(4) 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 67		Trustee		September 2006 — Present		Chair, Board of Directors and President, F.L. Putnam Securities Company, Inc. (June 1978 — Present).
Roger B. Vincent(4) 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 61		Trustee		September 2006 — Present		President, Springwell Corporation (March 1989 — Present).

[Additional columns below]

[Continued from above table, first column(s) repeated]

		Number of
		Funds
		in Fund
		Complex
		Overseen		Other Directorships
Name, Address and Age		by Trustee		held by Trustee
Independent Trustees:
John V. Boyer(2) 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 53		174		None
Patricia W. Chadwick(2) 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 58		174		Wisconsin Energy (June 2006 — Present).
J. Michael Earley(4) 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 61		174		Midamerica Financial Corporation (December 2002 — present).
R. Barbara Gitenstein(2) 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 59		174		None
Patrick W. Kenny(4) 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 64		174		Assured Guaranty Ltd. (April 2004 — Present); and Odyssey Reinsurance Holdings (November 2006 — Present).
Jock Patton(3) 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 61		174		JDA Software Group, Inc. (January 1999 — Present); and Swift Transportation Co. (March 2004 — Present).
Sheryl K. Pressler(4) 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 56		174		Stillwater Mining Company (May 2002 — Present); California HealthCare Foundation (June 1999 — Present); and Romanian-American Enterprise Fund (February 2004 — Present).
David W.C. Putnam(4) 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 67		174		Principled Equity Market Trust (December 1996 — Present); and Asian American Bank and Trust Company (June 1993 — Present).
Roger B. Vincent(4) 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 61		174		UGI Corporation (February 2006 — Present); and UGI Utilities, Inc. (February 2006 — Present).

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						Principal
		Position(s)		Term of Office		Occupation(s)
		held with		and Length of		during the Past
Name, Address and Age		Fund		Time Served(1)		Five Years
Trustees who are an “Interested Persons”:
Shaun P. Mathews(5) 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 51		Trustee		September 2006 — Present		President and Chief Executive Officer, ING Investments, LLC and ING Funds Services, LLC (December 2006 — Present); and Head of ING USFS Mutual Funds and Investment Products (October 2004 — Present). Formerly, CMO, ING USFS (April 2002 — October 2004); and Head of Rollover/ Payout (October 2001 — December 2003).
John G. Turner(5) 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 67		Trustee		September 2006 — Present		Retired.

[Additional columns below]

[Continued from above table, first column(s) repeated]

		Number of
		Funds
		in Fund
		Complex
		Overseen		Other Directorships
Name, Address and Age		by Trustee		held by Trustee
Trustees who are an “Interested Persons”:
Shaun P. Mathews(5) 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 51		4		Mark Twain House & Museum(3) (September 2002 — Present); Connecticut Forum (May 2002 — Present); Capital Community College Foundation (February 2002 — Present); ING Services Holding Company, Inc. (May 2000 — Present); Southland Life Insurance Company (June 2002 — Present); and ING Capital Corporation, LLC, ING Funds Distributor, LLC, ING Funds Services, LLC, ING Investments, LLC and ING Pilgrim Funding, Inc. (March 2006 — Present).
John G. Turner(5) 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 67		174		Hormel Foods Corporation (March 2000 — Present); and Conseco, Inc. (September 2003 — Present).

(1)	Trustees serve until their successors are duly elected and qualified, subject to the Board’s retirement policy.
(2)	Valuation, Proxy and Brokerage Committee member.
(3)	Shaun Mathews, President and Chief Executive Officer, ING Investments, LLC and ING Funds Services, LLC and Head of ING USFS Mutual Funds and Investment Products, has held a seat on the Board of Directors of The Mark Twain House & Museum since September 19, 2002. ING Groep makes non-material, charitable contributions to The Mark Twain House & Museum.
(4)	Audit Committee member.
(5)	Mr. Mathews and Mr. Turner are “interested persons,” as defined under the 1940 Act, because of their affiliation with ING Groep, the parent corporation of the Investment Adviser, ING Investments, LLC and the Distributor, ING Funds Distributor, LLC.

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				Term of Office
		Position(s) Held		and Length of		Principal Occupation(s)
Name, Address and Age		with the Fund		Time Served(1)		during the Past Five Years
Officers:
Shaun P. Mathews 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 51		President and Chief Executive Officer		November 2006 — Present		President and Chief Executive Officer, ING Investments, LLC and ING Funds Services, LLC (December 2006 — Present); and Head of ING USFS Mutual Funds and Investment Products (October 2004 — Present). Formerly, CMO, ING USFS (April 2002 — October 2004); and Head of Rollover/ Payout (October 2001 — December 2003).
Michael J. Roland 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 48		Executive Vice President		August 2006 — Present		Head of Mutual Fund Platform (February 2007 — Present); and Executive Vice President, ING Investments, LLC and ING Funds Services, LLC (December 2001 — Present). Formerly, Head of Product Management (January 2005 — January 2007); Chief Compliance Officer, ING Investments, LLC and Directed Services, LLC (October 2004 — December 2005); and Chief Financial Officer and Treasurer, ING Investments, LLC (December 2001 — March 2005).
Stanley D. Vyner 230 Park Ave. New York, New York 10169 Age: 56		Executive Vice President		August 2006 — Present		Executive Vice President, ING Investments, LLC (July 2000 — Present); and Chief Investment Risk Officer, ING Investments, LLC (January 2003 — Present). Formerly, Chief Investment Officer of the International Investments (August 2000 — January 2003).
Joseph M. O’Donnell 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 52		Executive Vice President and Chief Compliance Officer		August 2006 — Present		Chief Compliance Officer of the ING Funds (November 2004 — Present); ING Investments, LLC and Directed Services, LLC (March 2006 — Present); and Executive Vice President of the ING Funds (March 2006 — Present). Formerly, Chief Compliance Officer of ING Life Insurance and Annuity Company (March 2006 — December 2006); Vice President, Chief Legal Counsel, Chief Compliance Officer and Secretary of Atlas Securities, Inc., Atlas Advisers, Inc. and Atlas Funds (October 2001 — October 2004).
Robert S. Naka 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 43		Executive Vice President, Chief Operating Officer and Assistant Secretary		August 2006 — Present		Executive Vice President and Chief Operating Officer, ING Funds Services, LLC and ING Investments, LLC (March 2006 — Present); and Assistant Secretary, ING Funds Services, LLC (October 2001 — Present). Formerly, Senior Vice President, ING Investments, LLC (August 1999 — March 2006).
Todd Modic 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 39		Senior Vice President, Chief/Principal Financial Officer and Assistant Secretary		August 2006 — Present		Senior Vice President, ING Funds Services, LLC (April 2005 — Present). Formerly, Vice President, ING Funds Services, LLC (September 2002 — March 2005); and Director of Financial Reporting, ING Investments, LLC (March 2001 — September 2002).

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				Term of Office
		Position(s) Held		and Length of		Principal Occupation(s)
Name, Address and Age		with the Fund		Time Served(1)		during the Past Five Years
Kimberly A. Anderson 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 42		Senior Vice President		August 2006 — Present		Senior Vice President, ING Investments, LLC (October 2003 — Present). Formerly, Vice President and Assistant Secretary, ING Investments, LLC (January 2001 — October 2003).
Ernest J. C’DeBaca 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 37		Senior Vice President		August 2006 — Present		Senior Vice President, ING Investments, LLC (December 2006 — Present); and ING Funds Services, LLC (April 2006 — Present). Formerly, Counsel, ING Americas, U.S. Legal Services (January 2004 — March 2006); and Attorney-Adviser, U.S. Securities and Exchange Commission (May 2001 — December 2003).
Robert Terris 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 36		Senior Vice President		August 2006 — Present		Senior Vice President, Head of Division Operations, ING Funds (May 2006 — Present); and Vice President, Head of Division Operations, ING Funds Services, LLC (March 2006 — Present). Formerly, Vice President of Administration, ING Funds Services, LLC (October 2001 — March 2006).
Robyn L. Ichilov 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 39		Vice President and Treasurer		August 2006 — Present		Vice President and Treasurer, ING Funds Services, LLC (October 2001 — Present) and ING Investments, LLC (August 1997 — Present).
Lauren D. Bensinger 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 53		Vice President		August 2006 — Present		Vice President and Chief Compliance Officer, ING Funds Distributor, LLC (July 1995 — Present); and Vice President (February 1996 — Present); and Director of Compliance, ING Investments, LLC (October 2004 — Present). Formerly, Chief Compliance Officer, ING Investments, LLC (October 2001 — October 2004).
Maria M. Anderson 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 48		Vice President		August 2006 — Present		Vice President, ING Funds Services, LLC (September 2004 — Present). Formerly, Assistant Vice President, ING Funds Services, LLC (October 2001 — September 2004); and Manager of Fund Accounting and Fund Compliance, ING Investments, LLC (September 1999 — October 2001).
Denise Lewis 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 43		Vice President		January 2007 — Present		Vice President, ING Funds Services, LLC (December 2006 — Present). Formerly, Senior Vice President, UMB Investment Services Group, LLC (November 2003 — December 2006); and Vice President, Wells Fargo Funds Management, LLC (December 2000 — August 2003).

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				Term of Office
		Position(s) Held		and Length of		Principal Occupation(s)
Name, Address and Age		with the Fund		Time Served(1)		during the Past Five Years
Kimberly K. Palmer 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 49		Vice President		August 2006 — Present		Vice President, ING Funds Services, LLC (March 2006 — Present). Formerly, Assistant Vice President, ING Funds Services, LLC (August 2004 — March 2006); Manager, Registration Statements, ING Funds Services, LLC (May 2003 — August 2004); Associate Partner, AMVESCAP PLC (October 2000 — May 2003); and Director of Federal Filings and Blue Sky Filings, INVESCO Funds Group, Inc. (March 1994 — May 2003).
Susan P. Kinens 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 30		Assistant Vice President		August 2006 — Present		Assistant Vice President, ING Funds Services, LLC (December 2002 — Present); and has held various other positions with ING Funds Services, LLC for more than the last five years.
Huey P. Falgout, Jr. 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 43		Secretary		August 2006 — Present		Chief Counsel, ING Americas, U.S. Legal Services (September 2003 — Present). Formerly, Counsel, ING Americas, U.S. Legal Services (November 2002 — September 2003); and Associate General Counsel of AIG American General (January 1999 — November 2002).
Theresa K. Kelety 7337 E. Doubletree Ranch Rd. Scottsdale, Arizona 85258 Age: 44		Assistant Secretary		August 2006 — Present		Counsel, ING Americas, U.S. Legal Services (April 2003 — Present). Formerly, Senior Associate with Shearman & Sterling (February 2000 — April 2003).

(1)	The officers hold office until the next annual meeting of the Trustees and until their successors have been elected and qualified.

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Board Consideration and Approval of New Investment Management and Sub-Advisory Contracts

ING Risk Managed Natural Resources Fund (“IRR”) commenced operations in October 2006. In connection with its launch, IRR entered into an advisory arrangement with ING Investments, LLC (the “Adviser” or “ING Investments”) and a sub-advisory arrangement with ING Investment Management Co. (“ING IM” or the “Sub-Adviser”). Section 15 of the Investment Company Act of 1940 (the “1940 Act”) mandates that IRR’s Board of Trustees (the “Board”), including a majority of the Trustees who have no direct or indirect interest in the Investment Management and Sub-Advisory Agreements governing IRR’s advisory and sub-advisory arrangements, and who are not “interested persons” of IRR, as such term is defined under the 1940 Act (the “Independent Trustees”), approve the new Agreements for IRR prior to the commencement of its operations.

At a telephonic meeting held on September 11, 2006 and an in-person meeting held on September 21, 2006 (the “September Meetings”), the Board considered the approval of IRR’s Investment Management and Sub-Advisory Agreements. After its deliberations, at the September 21, 2006 meeting the Board voted to approve these Agreements for initial terms that end on November 30, 2007. In reaching this decision, the Board took into account information prepared in connection with the Board’s deliberations in September with respect to the approval of IRR’s advisory and sub-advisory arrangements. The Board’s determination took into account a number of factors that its members believed, in light of the legal advice furnished to them by Kirkpatrick & Lockhart Nicholson Graham LLP (“K&LNG”), their independent legal counsel, and their own business judgment, to be relevant. Further, while IRR’s Investment Management Agreement and Sub-Advisory Agreement were considered at the same Board meeting, the Trustees considered IRR’s advisory and sub-advisory relationships separately.

Provided below is a discussion of certain factors the Board considered at the September Meetings in considering IRR’s advisory and sub-advisory arrangements. While the Board gave its attention to the information furnished, at its request, that was most relevant to its deliberations, discussed below are a number of the primary factors relevant to the Board’s consideration as to whether to approve the Investment Management and Sub-Advisory Agreements on behalf of IRR. Each Trustee may have accorded different weight to the various factors in reaching his or her conclusions with respect to these Agreements.

Overview of the Contract Approval Process

The Board has established a process under which it reviews and analyzes information in connection with its evaluation and approval of new advisory and sub-advisory relationships. In accordance with this process, certain types of information must be presented to the Board to inform its deliberations with respect to advisory and sub-advisory arrangements, in a specified format.

The type and format of the information provided to the Board or its counsel to inform the Board’s approval process has been codified in the “15(c) Methodology Guide” (the “Methodology Guide”) for the Funds in the ING Funds complex. The Methodology Guide was developed under the direction of the Independent Trustees, and sets out a written blueprint under which the Independent Trustees request certain information necessary to facilitate a thorough and informed review in connection with its advisory and sub-advisory agreement approval process. The Adviser or its affiliates who administer the Funds in the ING Funds complex (“Management”) provide Fund-specific information to the Independent Trustees based on the Methodology Guide through “Fund Analysis and Comparison Tables” or “FACT” sheets prior to the Independent Trustees’ review of advisory and sub-advisory contracts for the Funds.

The Board employed its process for reviewing contracts when considering the approvals of the Investment Management and Sub-Advisory Agreements for IRR. A number of the Board’s primary considerations and conclusions resulting from this process are discussed below.

Nature, Extent and Quality of Service

In determining whether to approve the Investment Management and Sub-Advisory Agreements for IRR for their initial terms ending November 30, 2007, the Independent Trustees received and evaluated such information as they deemed necessary regarding the nature, extent and quality of services to be provided to IRR by ING Investments and ING IM. This included information furnished for the September Meetings,

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which were held specifically to consider, among other things, approval of IRR’s Investment Management and Sub-Advisory Agreements for initial periods ending November 30, 2007.

The materials requested by and provided to the Board and/or to K&LNG prior to the September Meetings included the following items: (1) FACT sheets for IRR that provided information about the IRR’s proposed expenses and those of other, similarly managed funds in a selected peer group (“Selected Peer Group”), as well as information about IRR’s proposed objectives and strategies; (2) responses from ING Investments and ING IM to a detailed series of questions from K&LNG; (3) copies of the forms of proposed Investment Management Agreement and Sub-Advisory Agreement; (4) a draft of a narrative summary addressing key factors the Board could consider in determining whether to approve the new Investment Management and Sub-Advisory Agreements; and (5) other information relevant to the Board’s evaluations.

In considering IRR’s Investment Management and Sub-Advisory Agreements, the Board took into account the extent of benefits to be provided to IRR’s shareholders, beyond advisory services, from being part of the ING family of Funds. The Board also considered reports from IRR’s Chief Compliance Officer (“CCO”) evaluating the regulatory compliance systems of ING Investments and ING IM and procedures reasonably designed by them to assure compliance with the federal securities laws, including those related to late trading and market timing, best execution, fair value pricing, proxy voting procedures, and trade allocation, among others. In this regard, the Board took into account the policies and procedures developed by the CCO in consultation with the Board’s Compliance Committee that guide the CCO’s compliance oversight function.

The Board reviewed the level of staffing, quality and experience of IRR’s proposed portfolio management team. The Board took into account the respective resources and reputations of ING Investments and ING IM, and evaluated the ability of ING Investments and ING IM to attract and retain qualified investment advisory personnel. The Board also considered the adequacy of the resources to be committed to IRR by ING Investments and ING IM, and whether those resources are commensurate with IRR’s needs and are appropriate to attempt to sustain expected levels of performance, compliance, and other needs.

Based on its deliberations and the materials presented, the Board concluded that the advisory, sub-advisory and related services to be provided by ING Investments and ING IM would be appropriate in light of IRR’s anticipated operations, the competitive landscape of the investment company business, and investor needs, and that the nature and quality of the overall services provided by ING Investments and ING IM would be appropriate.

Economies of Scale

In considering the reasonableness of advisory fees, the Board also considered whether economies of scale will be realized by the Adviser as IRR grows larger and the extent to which this is reflected in the level of management fee rates charged. In this regard, the Board considered the fairness of the compensation under an Investment Management Agreement with level fees that does not include breakpoints, taking into account that IRR is a closed-end Fund.

Fee Rates and Profitability

The Board reviewed and considered the proposed contractual advisory fee rate, combined with the administrative fee rate, payable by IRR to ING Investments. The Board also considered the proposed contractual sub-advisory fee rate payable by ING Investments to ING IM for sub-advisory services.

The Board considered IRR’s proposed fee structure as it relates to the services to be provided under the Investment Management and Sub-Advisory Agreements, and the potential fall-out benefits to ING Investments and ING IM, and their respective affiliates, from their association with IRR. The Board determined that the fees payable to ING IM for its services to IRR are reasonable for such services, which were considered in light of the nature and quality of the services that each is expected to perform through the initial term ending November 30, 2007.

The Board considered information on estimated revenues, costs and profits for ING Investments projected for the first two years of IRR’s operations. In analyzing the projected profitability of ING Investments in connection with its services to IRR, the Board took into account the sub-advisory fee rate to be payable by ING Investments to ING IM. The Board also considered information that it requested and was provided by Management with respect to the profitability of service providers affiliated with ING Investments.

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The Board determined that it had requested and received sufficient information to gain a reasonable understanding regarding ING Investments’ profitability. The Board also recognized that profitability analysis is not an exact science and there is no uniform methodology for determining profitability for this purpose. In this context, the Board realized that Management’s calculations regarding its costs incurred in establishing the infrastructure necessary for IRR’s operations may not be fully reflected in the expenses allocated to IRR in determining profitability, and that the information presented may not portray all of the costs borne by Management nor capture Management’s entrepreneurial risk associated with offering and managing a mutual fund complex in today’s regulatory environment.

Based on the information on revenues, costs, and ING Investments’ profitability considered by the Board, after considering the factors described in this section the Board concluded that the profits, if any, to be realized by ING Investments would not be excessive.

Other Factors Considered

The following paragraphs outline certain of the specific factors that the Board considered, and the conclusions reached, at its September 21, 2006 meeting in relation to approving the Investment Management and Sub-Advisory Agreements for IRR’s initial term ending November 30, 2007. These specific factors are in addition to those considerations discussed above. IRR’s proposed management fee and estimated expense ratio were compared to the fees and expense ratios of the funds in its Selected Peer Group.

In determining whether to approve ING Risk Managed Natural Resources Fund’s Investment Management Agreement and Sub-Advisory Agreement for their initial terms, the Board received and evaluated such information as it deemed necessary for an informed determination of whether each Agreement, and the proposed policies and procedures for IRR, should be approved for IRR. The materials provided to the Board and/or K&LNG prior to the September Meetings in support of the proposed advisory and sub-advisory arrangements included the following: (1) a memorandum presenting Management’s rationale for requesting the launch of IRR; (2) information about IRR’s proposed investment portfolio, objectives and strategies; (3) responses from ING Investments and ING IM to questions posed by K&LNG; (4) supporting documentation, including copies of the forms of Investment Management and Sub-Advisory Agreements for IRR; and (5) other information relevant to the Board’s evaluation.

In determining whether to approve the Investment Management and Sub-Advisory Agreements for IRR, the Board considered a number of factors that its members believed, in light of the legal advice furnished to them by K&LNG and their own business judgment, to be relevant. The Board, including a majority of the Independent Trustees, did not identify any single factor as all-important or controlling, and each member of the Board may have given different weight to different factors.

The Board’s consideration of whether to approve the Investment Management Agreement took into account factors that included the following: (1) the nature and quality of the services to be provided by ING Investments to IRR under the proposed Investment Management Agreement; (2) ING Investments’ experience as a manager-of-managers overseeing sub-advisers to other Funds within the ING Funds complex, including other closed-end Funds; (3) ING Investments’ strength and reputation within the industry; (4) the fairness of the compensation under the Investment Management Agreement in light of the services to be provided to IRR and taking into account the sub-advisory fees payable by ING Investments to ING IM; (5) the pricing structure (including the projected expenses to be borne by shareholders) of IRR, as compared to other similarly-managed funds in a comparable Selected Peer Group, including Management’s analysis that (a) IRR’s proposed management fee (inclusive of the advisory fee and a 0.10% administration fee ) is above the average and median advisory fees of the funds in IRR’s Selected Peer Group, and (b) the projected expense ratio for IRR is below the average and above the median expense ratios of the funds in IRR’s Selected Peer Group; (6) the projected profitability of ING Investments when sub-advisory fees payable by ING Investments to ING IM are taken into account; (7) the personnel, operations, financial condition, and investment management capabilities, methodologies and resources of ING Investments, including its management team’s expertise in the management of other Funds, including closed-end Funds; (8) ING Investments’ compliance capabilities, as demonstrated by, among other things, its policies and procedures adopted pursuant to Rule 206(4)-7 under the

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Investment Advisers Act of 1940, which had previously been approved by the Board in connection with their oversight of other Funds in the ING Funds complex; (9) the information that had been provided by ING Investments in anticipation of the September Meetings with respect to its capabilities as a manager-of-managers; (10) “fall-out benefits” to ING Investments and its affiliates and benefits to the shareholders from IRR’s relationship with ING Investments; and (11) ING Investments’ ability to negotiate an offering underwritten by a syndicate of well-known, successful financial service providers led by Citigroup.

In reviewing the proposed Sub-Advisory Agreement with ING IM, the Board considered a number of factors, including, but not limited to, the following: (1) ING Investments’ view of ING IM’s as a manager to other Funds in the ING Funds complex, including two recently-launched closed-end Funds; (2) ING IM’s strength and reputation in the industry; (3) ING IM’s experience and skill in managing other closed-end Fund offerings; (4) the information that had been provided by ING IM in anticipation of the September 11, 2006 telephonic meeting and the September 21, 2006 in-person meeting at which the Sub-Advisory Agreement was considered with respect to its sub-advisory services in general and its management of closed-end Funds in particular; (5) the nature and quality of the services to be provided by ING IM under the proposed Sub-Advisory Agreement; (6) the personnel, operations, financial condition, and investment management capabilities, methodologies and resources of ING IM, including its management team’s expertise in the management of closed-end Funds specializing in the types of equity investment and options strategies in which IRR would engage; (7) the fairness of the compensation under the Sub-Advisory Agreement in light of the services to be provided by and the projected profitability of ING IM as IRR’s sub-adviser; (8) the costs for the services to be provided by ING IM; (9) ING IM’s operations and compliance program, including its policies and procedures adopted pursuant to Rule 206(4)-7 under the 1940 Act, which had previously been approved by the Board as part of its oversight of other Funds in the ING Funds complex; (10) ING IM’s financial condition; (11) the appropriateness of the selection of ING IM in light of IRR’s investment objectives and prospective investor base; and (12) ING IM’s Code of Ethics, which had previously been approved for other ING Funds, and related procedures for complying with that Code.

After its deliberation, the Board reached the following conclusions: (1) IRR’s proposed management fee rate is reasonable in the context of all factors considered by the Board; (2) IRR’s estimated expense ratio is reasonable in the context of all factors considered by the Board; (3) the sub-advisory fee rate payable by ING Investments to ING IM is reasonable in the context of all factors considered by the Board; and (4) each of ING Investments and ING IM maintains an appropriate compliance program, with this conclusion based upon the Board’s previous and ongoing review of the compliance program. Based on these conclusions and other factors, the Board voted to approve the Investment Management and Sub-Advisory Agreements for IRR. During their deliberations, different Board members may have given different weight to different individual factors and related conclusions.

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During the period, there were no material changes in the Fund’s investment objective or policies that were not approved by the shareholders or the Fund’s charter or by-laws or in the principal risk factors associated with investment in the Fund. There have been no changes in the persons who are primarily responsible for the day-to-day management of the Fund’s portfolio.

Dividend Reinvestment Plan

Unless the registered owner of Common Shares elects to receive cash by contacting The Bank of New York (the “Plan Agent”), all dividends declared on Common Shares of the Fund will be automatically reinvested by the Plan Agent for shareholders in additional Common Shares of the Fund through the Fund’s Dividend Reinvestment Plan (the “Plan”). Shareholders who elect not to participate in the Plan will receive all dividends and other distributions in cash paid by check mailed directly to the shareholder of record (or, if the Common Shares are held in street or other nominee name, then to such nominee) by the Plan Agent. Participation in the Plan is completely voluntary and may be terminated or resumed at any time without penalty by notice if received and processed by the Plan Agent prior to the dividend record date; otherwise such termination or resumption will be effective with respect to any subsequently declared dividend or other distribution. Some brokers may automatically elect to receive cash on your behalf and may re-invest that cash in additional Common Shares of the Fund for you. If you wish for all dividends declared on your Common Shares of the Fund to be automatically reinvested pursuant to the Plan, please contact your broker.

The Plan Agent will open an account for each Common Shareholder under the Plan in the same name in which such Common Shareholder’s Common Shares are registered. Whenever the Fund declares a dividend or other distribution (together, a “Dividend”) payable in cash, non-participants in the Plan will receive cash and participants in the Plan will receive the equivalent in Common Shares. The Common Shares will be acquired by the Plan Agent for the participants’ accounts, depending upon the circumstances described below, either (i) through receipt of additional unissued but authorized Common Shares from the Fund (“Newly Issued Common Shares”) or (ii) by purchase of outstanding Common Shares on the open market (“Open-Market Purchases”) on the NYSE or elsewhere. Open-market purchases and sales are usually made through a broker affiliated with the Plan Agent.

If, on the payment date for any Dividend, the closing market price plus estimated brokerage commissions per Common Share is equal to or greater than the net asset value per Common Share, the Plan Agent will invest the Dividend amount in Newly Issued Common Shares on behalf of the participants. The number of Newly Issued Common Shares to be credited to each participant’s account will be determined by dividing the dollar amount of the Dividend by the net asset value per Common Share on the payment date; provided that, if the net asset value is less than or equal to 95% of the closing market value on the payment date, the dollar amount of the Dividend will be divided by 95% of the closing market price per Common Share on the payment date. If, on the payment date for any Dividend, the net asset value per Common Share is greater than the closing market value plus estimated brokerage commissions, the Plan Agent will invest the Dividend amount in Common Shares acquired on behalf of the participants in Open-Market Purchases. In the event of a market discount on the payment date for any Dividend, the Plan Agent will have until the last business day before the next date on which the Common Shares trade on an “ex-dividend” basis or 30 days after the payment date for such Dividend, whichever is sooner (the “Last Purchase Date”), to invest the Dividend amount in Common Shares acquired in Open-Market Purchases.

It is contemplated that the Fund will pay monthly income Dividends. Therefore, the period during which Open-Market Purchases can be made will exist only from the payment date of each Dividend through the date before the next “ex-dividend” date, which typically will be approximately ten days.

If, before the Plan Agent has completed its Open-Market Purchases, the market price per common share exceeds the net asset value per Common Share, the average per Common Share purchase price paid by the Plan Administrator may exceed the net asset value of the Common Shares, resulting in the acquisition of fewer Common Shares than if the Dividend had been paid in Newly Issued Common Shares on the Dividend payment date. Because of the foregoing difficulty with respect to Open-Market Purchases, the Plan provides that if the Plan Agent is unable to invest the full Dividend amount in Open-Market Purchases during the purchase period or if the market discount shifts to a market premium during the purchase period, the Plan Agent will cease making Open-

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Market Purchases and will invest the un-invested portion of the Dividend amount in Newly Issued Common Shares at the net asset value per common share at the close of business on the Last Purchase Date provided that, if the net asset value is less than or equal to 95% of the then current market price per Common Share, the dollar amount of the Dividend will be divided by 95% of the market price on the payment date.

The Plan Agent maintains all shareholders’ accounts in the Plan and furnishes written confirmation of all transactions in the accounts, including information needed by shareholders for tax records. Common Shares in the account of each Plan participant will be held by the Plan Agent on behalf of the Plan participant, and each shareholder proxy will include those shares purchased or received pursuant to the Plan. The Plan Agent will forward all proxy solicitation materials to participants and vote proxies for shares held under the Plan in accordance with the instructions of the participants.

In the case of shareholders such as banks, brokers or nominees which hold shares for others who are the beneficial owners, the Plan Agent will administer the Plan on the basis of the number of Common Shares certified from time to time by the record shareholder’s name and held for the account of beneficial owners who participate in the Plan.

There will be no brokerage charges with respect to Common Shares issued directly by the Fund. However, each participant will pay a pro rata share of brokerage commissions incurred in connection with Open-Market Purchases. The automatic reinvestment of Dividends will not relieve participants of any federal, state or local income tax that may be payable (or required to be withheld) on such Dividends. Participants that request a partial or full sale of shares through the Plan Agent are subject to a $15.00 sales fee and a $0.10 per share brokerage commission on purchases or sales, and may be subject to certain other service charges.

The Fund reserves the right to amend or terminate the Plan. There is no direct service charge to participants with regard to purchases in the Plan; however, the Fund reserves the right to amend the Plan to include a service charge payable by the participants.

All questions concerning the Plan should be directed to the Fund’s Shareholder Service Department at 1-800-992-0180.

KEY FINANCIAL DATES — CALENDAR 2007 DIVIDENDS:

DECLARATION DATE		EX-DIVIDEND DATE		PAYABLE DATE
March 23		April 2		April 16
June 22		July 2		July 16
September 21		October 1		October 15
December 21		December 31		January 15

Record date will be two business days after each Ex-Dividend Date. These dates are subject to change.

Stock Data

The Fund’s common shares are traded on the NYSE (Symbol: IRR).

Repurchase of Securities by Closed-End Companies

In accordance with Section 23(c) of the 1940 Act, and Rule 23c-1 under the 1940 Act the Fund may from time to time purchase shares of beneficial interest of the Fund in the open market, in privately negotiated transactions and/or purchase shares to correct erroneous transactions.

Number of Shareholders

The approximate number of record holders of Common Stock as of February 28, 2007 was 21,318, which does not include beneficial owners of shares held in the name of brokers of other nominees.

Proxy Voting Information

A description of the policies and procedures that the Fund uses to determine how to vote proxies related to portfolio securities is available (1) without charge, upon request, by calling Shareholder Services toll-free at 1-800-992-0180; (2) on the Fund’s website at www.ingfunds.com and (3) on the SEC’s website at www.sec.gov. Information regarding how the Fund voted proxies related to portfolio securities during the most recent 12-month period ended June 30 is available without charge on the Fund’s website at www.ingfunds.com and on the SEC’s website at www.sec.gov.

Quarterly Portfolio Holdings

The Fund files its complete schedule of portfolio holdings with the SEC for the first and third quarters

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of each fiscal year on Form N-Q. The Fund’s Forms N-Q are available on the SEC’s website at www.sec.gov. The Fund’s Forms N-Q may be reviewed and copied at the SEC’s Public Reference Room in Washington, DC, and information on the operation of the Public Reference Room may be obtained by calling 1-800-SEC-0330; and is available upon request from the Fund by calling Shareholder Services toll-free at 1-800-992-0180.

Certifications

In accordance with Section 303A.12 (a) of the New York Stock Exchange Listed Company Manual, the Fund submitted the Annual CEO Certification on September 21, 2006 certifying that he was not aware, as of that date, of any violation by the Fund of the NYSE’s Corporate governance listing standards. In addition, as required by Section 302 of the Sarbanes-Oxley Act of 2002 and related SEC rules, the Fund’s principal executive and financial officers have made quarterly certifications, included in filings with the SEC on Forms N-CSR and N-Q, relating to, among other things, the Fund’s disclosure controls and procedures and internal controls over financial reporting.

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Administrator

Distributor

Transfer Agent

Independent Registered Public

Custodian

Legal Counsel

Toll-Free Shareholder Information

	PRAR-UIRR          (0207-042607)

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