Report of Independent Auditors
To the shareholders and Board of Trustees of ING Funds Trust:
In planning and performing our audit of the financial statements of
ING Internet Fund, ING Small Cap Growth Fund, ING Focus Fund, ING
Mid Cap Growth Fund, ING Large Cap Growth Fund, ING Tax Efficient
Equity Fund, ING Growth & Income Fund, ING International Bond Fund,
ING Global Information Technology Fund, ING European Equity Fund,
ING International Equity Fund, ING Global Brand Names Fund, ING High
Yield Bond Fund, ING Intermediate Bond Fund, ING Emerging Markets
Equity Fund, ING Global Communications Fund, ING National Tax-Exempt
Bond Fund and ING Money Market Fund (eighteen of the portfolios
constituting ING Funds Trust) (collectively, the "Funds") for the
period ended October 31, 2000, we considered its internal control,
including control activities for safeguarding securities, in order
to determine our auditing procedures for the purpose of expressing
our opinions on the financial statements and to comply with the
requirements of Form N-SAR, not to provide assurance on internal
control.
The management of the Funds is responsible for establishing and
maintaining internal control. In fulfilling this responsibility,
estimates and judgements by management are required to assess the
expected benefits and related costs of controls. Generally, controls
that are relevant to an audit pertain to the entity's objective of
preparing financial statements for external purposes that are fairly
presented in conformity with generally accepted accounting principles.
Those controls include the safeguarding of assets against unauthorized
acquisition, use of disposition.
Because of inherent limitations in internal control, errors or fraud
may occur and not be detected. Also, projection of any evaluation of
internal control to future periods is subject to the risk that it may
become inadequate because of changes in conditions or that the
effectiveness of the design and operation may deteriorate.
Our consideration of internal control would not necessarily disclose
all matters in internal control that might be material weaknesses
under standards established by the American Institute of Certified
Public Accountants. A material weakness is a condition in which the
design or operation of one or more of the specific internal control
components does not reduce to relatively low level the risk that
misstatements caused by errors or fraud in amounts that would be
material in relation to the financial statements being audited may
occur and not be detected within a timely period by employees in the
normal course of performing their assigned functions. However, we
noted no matters involving internal control and its operation,
including controls for safeguarding securities, that we consider to
be material weaknesses as defined above at October 31, 2000.
This report is intended solely for the information and use of
management, the Board of Trustees of the Funds, and the Securities
and Exchange Commission and is not intended to be and should not be
used by anyone other than these specified parties.
Ernst & Young LLP
New York, New York
December 5, 2000
