4.9.2007 The SEC brought administrative and cease-and-desist proceedings against Geoffrey Brod. Brod was formerly a portfolio manager at Aeltus Investment Management, LLC (now known as ING Investment Management Co.), a registered investment adviser. The SEC alleges that, from 1999 to 2003, Brod concealed his own stock trading, including trading in stocks held by mutual funds he managed, by failing to disclose his trades and falsifying internal reports. During this period, Brod executed but failed to disclose approximately 3,500 trades in public company stocks that made about $410,000 in profit.

The SEC alleges that through this conduct, Brod willfully violated Section 17(j) of the Investment Company Act of 1940 and Rules 17j-1(b) and 17j-1(d) thereunder. A hearing will be scheduled before an Administrative Law Judge to determine whether these allegations are true, to afford the respondent an opportunity to establish defenses to the allegations, to determine whether remedial action is appropriate and in the public interest, to determine whether respondent should be ordered to cease and desist from committing or causing violations of and any future violations of the securities laws, and to determine whether respondent should be ordered to pay disgorgement.

Please click http://www.sec.gov/divisions/investment/noaction/2007/gsam031307-3c7.htm to access a copy of the no-action letter.