ING Funds Distributor, Inc.
230 Park Avenue
New York, New York 10169
(212) 309-8650
June 22, 2000
VIA EDGAR
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Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: Insured Municipal Securities Trust, New York
Navigator Insured Series 13
File No. 33-56918
Gentlemen:
As Sponsor of the above-referenced Trust, we are writing this
letter to certify that:
(1) the form of Prospectus that would have been filed under Rule
497(b) of the Securities Act of 1933 does not differ from that contained in the
most recent Post-Effective Amendment to the Registration Statement on Form S-6
(the "Registration Statement"), and
(2) the text of the most recent Registration Statement was filed
electronically with the Securities and Exchange Commission on April 28, 2000 and
became effective April 29, 2000 pursuant to Rule 485(b).
Insured Municipal Securities Trust,
New York Navigator Insured Series 13
ING Funds Distributor, Inc.
By: /s/ Peter J. DeMarco
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Peter J. DeMarco
Authorized Signatory
NYC55/4717.1
