ING Fixed Income Managed Accounts Intermediate Strategy

1. ING Fixed Income Managed AccountsIntermediate Strategy For financial professional use only. Not for inspection by, distribution or quotation to, the general public. Separately Managed Account Quarter ending March 31, 2012 www.inginvestment.com CAID #2324

2. Bank of America Corporation (“Bank of America”) is a financial holding company that, through its subsidiaries and affiliated companies, provides banking and investment products and other financial services . Merrill Lynch, Pierce, Fenner & Smith Incorporated is a wholly-owned subsidiary of Bank of America Corporation, and a registered broker-dealer and member of FINRA and SIPC. Investment products provided by Merrill Lynch, Pierce, Fenner & Smith, Incorporated: The views and opinions expressed in this presentation are not necessarily those of Bank of America Corporation; Merrill Lynch, Pierce, Fenner & Smith Incorporated; or any affiliates. Nothing discussed or suggested in these materials should be construed as permission to supersede or circumvent any Bank of America, Merrill Lynch, Pierce, Fenner & Smith Incorporated policies, procedures, rules, and guidelines. Merrill Lynch, Pierce, Fenner & Smith Incorporated are not tax or legal advisors. Clients should consult a personal tax or legal advisor prior to making any tax or legal related investment decisions. For Investment Professional Use Only

3. Managed Accounts Fixed Income Investment Team

4. Intermediate SMA Investment Objectives • Objective • Seeks to provide total return while preserving capital, largely through the use of Treasuries, Agencies and Corporate credit securities of 1-10 year maturities • Strategy • Diversified top-down, theme driven investment approach: returns come from numerous sources • Interest rate and yield curve positioning • Sector allocations • Relative value security analysis • Proprietary research generates original ideas • Buy Discipline • Top-down bond selection based on economic and interest rate outlook • Holdings adjusted as outlook is revisited and environment changes • Sell Discipline • Evaluate credit quality continuously and sell deteriorating credits • Sell bonds that exceed their relative value • Sell bonds that are no longer consistent with the macro outlook • Risk Control • Measured portfolio duration shifts based on long-term economic outlook • Preference for liquid bonds from well-established corporations and government agencies • Little exposure to extremely rate-sensitive bonds with high durations or structured products

5. Investment Grade Investment Process Economic Analysis and Understanding Formation of Market View Interest Rates, Yield Curve and Sector Outlook Yield Curve Positioning Sector Allocation Industry Selection Relative Value/ Fundamental Research On-going Evaluation of Relative Value and Macro Views Specific Security Selection Portfolio Construction

6. Investment Process Critical Decisions • Interest rate trend determines duration • Strongest driver of investment grade fixed income performance • Measured portfolio maturity shifts based on long-term economic outlook • Yield curve • Strategy based on expectations of government policy, economic growth and inflation • Portfolio holdings are adjusted based on anticipated yield curve shape • Sector • Relative value assessments: across governments, mortgages and corporates • Provides opportunity to lower risk through diversification and increases total return potential • Industry • Industry financial outlook relative to overall macroeconomic outlook • Stack ranking firms within industries • Issue selection • Credit worthiness and relative value • Process largely limited liquid investment grade bonds

7. Interest Rate Trend Determines Duration • Measured maturity/duration shifts based on long-term economic outlook • Limit maturity/duration shifts to generally to 20% of client benchmark • Weekly formal evaluation of investment outlook Disciplined Interest Rate Anticipation Financial Economy Real Economy • Growth • Savings • Fiscal Policy • Demographics • Real Rates • Capital Flows • Inflation • Monetary Policy Investment Outlook Negative Neutral Positive • Rates higher • Rates stable • Rates lower Range Duration Benchmark Duration -20% +20%

8. The Active Duration Decision Profit from changes in market interest rates–examples of duration adjustments 4.5 5.5% • Historical example indicative of investment process that seeks total return from anticipating interest rate environment. • ING Investment Management added interest rate risk (duration) early in the period and took off the trade later in the period. 4.0 5.0% Yield Duration (years) 3.5 4.5% (left scale) ING duration (left scale) Benchmark duration (right scale) 10-Yr T-note yield 3.0 4.0% Dec-00 Jan-01 Feb-01 Mar-01 Apr-01 May-01 Jun-01 Jul-01 Aug-01 Sep-01 Oct-01 Nov-01 Dec-01 ING Investment Management Duration: Representative account in ING Intermediate Fixed Income Strategy. Benchmark Duration: Lehman Intermediate Government Corporate Index (constant at 3.7 years). Data source: Bloomberg. We deem this to be a reliable source but accuracy and completeness cannot be guaranteed. Data in this chart are as of December 31, 2001. This portfolio was selected as a representative portfolio in order to demonstrate our investment process. ING Investment Management did not use performance-based criteria in its selection. Duration is dynamic and subject to change at any time. The duration variations of other client portfolios may differ from the portfolio illustrated here. Past performance is not indicative of future results.

9. In a flattening, Barbell can outperform Bullet 6/05 Yield % Yield % X Barbell 12/04 Average Portfolio Maturity(years) Average Portfolio Maturity(years) Yield Curve Decision • Implementation of duration • Yield curve strategy based on fundamental outlook for: • Federal Reserve Policy • Treasury Supply • Economic Growth • Inflation • “Bullet” structures generally have a yield advantage over “barbell” or “blanket” structures Cost of Barbell is a lower yield For Illustrative Purposes Only Total returns for six month period 12/04 – 6/05: bullet two-year U.S. Treasury = 0.723% Barbelled identical duration combination of three-month bill and five-year U.S. Treasury = 1.26%, or 0.54% better. Source of performance data: Bloomberg, Inc; used with permission. We deem this to be a reliable source but cannot guarantee accuracy and completeness. Past performance is no guarantee of future results. This has been prepared by ING Investment Management for informational purposes. Nothing contained herein should be construed as (i) an offer to sell or solicitation of an offer to buy any security or (ii) a recommendation as to the advisability of investing in, purchasing or selling any security. Any opinions expressed herein reflect our judgment at this date and are subject to change.

10. Sector Decision Representative Sector Allocation* (%) High quality sectors • U.S. Treasuries • Federal agencies • Investment-grade corporates • Mortgage-backed • Asset-backed Multiple sector approach • Lowers risk through diversification • Increases total return potential *The actual asset allocation of portfolios may vary depending on investor objectives, respective strategy and market conditions

11. Industry Selection • Assessment of industry fundamentals based on economic environment and industry strength • Some industries can be significant holdings, while others may be totally avoided • Stack-ranking approach • Bias to selecting strongest players in each industry • May drill deeper down in strongest industries • Function of economic and industry outlook We believe the above named issuers are examples of the strongest companies in their particular industry based on their fundamentals of financial strength. Nothing contained herein should be construed as (i) an offer to sell or solicitation of an offer to buy any security or (ii) a recommendation as to the advisability of investing in, purchasing or selling any security. Any opinions expressed herein reflect our judgment at this date and are subject to change. These holdings may not reflect the actual holdings of other Fixed Income portfolios managed by ING Investment Management . Past performance is not indicative of future results.

12. Issue Selection Process for All Investment Grade Strategies Fundamental Research Relative Value Screening Joint Review Bond market is OTC: efficient execution can add value Systems, Compliance and Technology Seasoned Judgment Screening Procedures Model Portfolio

13. Managed Account Customization • To the extent that we can, we want our investment approach to address a clients risk tolerances and reward expectations • Distinct from only an “off the shelf” product approach, we want to customize a solution for a “consultative sale” if practical • Typically, these approaches work by constraining our “one contract” platform product to the specific requirements desired • The guidelines can be constrained to fit specific investment needs; for example: • Short –Term MA • Shorter bond maturities held in the portfolio that target a duration range of 1 and 5 years • Government Only MA • Excludes all corporate credit within the portfolio and has an average AAA quality rating

14. Model Portfolio as of March 31, 2012 This is a sample Intermediate Fixed Income portfolio. One account was selected by our portfolio managers as a representative account that best represents this investment style. ING Investment Management did not use performance-based criteria in determining which account to include. These holdings represent only a sample portfolio and may not reflect the actual holdings of other Intermediate Fixed Income portfolios managed by ING Investment Management . The performance of other Intermediate Fixed Income portfolios may be better or worse than that of this sample portfolio. Past performance is not indicative of future results.

15. Portfolio Characteristics as of March 31, 2012 *For information purposes only and not a recommendation to purchase or sell any security. It should not be assumed that securities held in the future will be profitable or will equal the performance of the securities mentioned herein. One account was selected by our portfolio managers as a representative account that generally best represents this investment management style. Actual holdings of other Intermediate Fixed Income portfolios managed by ING Investment Management may differ. ING Investment Management did not use performance-based criteria in determining which account to include. The performance of other Intermediate Fixed Income portfolios may be better or worse than that of this sample portfolio. The information contained herein is as of the above date, unless otherwise noted.

16. ING Intermediate Fixed Income Merrill Lynch as of March 31, 2012 Annual Returns Annualized Total Returns(1) * Preliminary returns. Index= Merrill Lynch Corp & Govt 1-10 Yr. One cannot invest directly in an index. The performance information shown is calculated by Merrill Lynch and taken unmodified from the Merrill Consults profile for ING Intermediate Fixed Income. Gross returns are presented before the wrap fee is deducted. Returns include the reinvestment of income. Net performance is shown after the this strategy in compliance with GIPS standards. Index source: FactSet. Index return source: Factset. We deem this to be a reliable source, but accuracy and completeness cannot be guaranteed. Gross of Fee returns are “Pure Gross” and do not reflect the deduction of transaction costs associated with investment.ING Investment Management calculates its own performance results for guarantee accuracy and completeness. Indices are unmanaged and one cannot invest directly in an index. Past performance does not guarantee or indicate future results.

17. Appendix

18. Fixed Income Investment Management Team Richard C. Kilbride Head of Fixed Income for Managed Accounts Years of investment experience: 32 Rick Kilbride joined ING Investment Management’s predecessor firm Furman Selz in 2001 as head of fixed income. Upon integration into ING Investment Management he assumed responsibility for the investment grade managed account business. Previously, he spent 12 years at Merrill Lynch, most recently leading an investment team managing leveraged loans and high-yield bonds. He also was the London-based managing director of Merrill’s global institutional separate account fixed income portfolio management business. Before that, he was responsible for Merrill's initial efforts to build a U.S. institutional fixed income separate account presence, served as chief investment strategist of its captive insurance company, and was the asset-liability manager of Merrill Lynch Bank and Trust. He served on the board of directors of that bank for five years. Previously, he was a vice president in Paine Webber's institutional fixed income sales and trading business and began his career as an analyst on General Motors’ New York treasury staff. Rick holds a B.A. from Colorado College (where he has also taught) and an M.B.A. from the Amos Tuck School at Dartmouth College. He is a member of the CFA Institute and the New York Society of Security Analysts. Karen Cronk Senior Portfolio Manager Years of investment experience: 27 Karen Cronk is a Senior Portfolio Manager providing leadership in the determination of portfolio strategy and structure. She is also responsible for implementing the portfolio construction and trading strategies. Additionally, she manages the fixed income group’s analytics and modeling. Karen joined ING Investment Management’s predecessor firm in February of 1995. Previously, Karen was a senior portfolio manager at Bankers Trust with responsibility for managing short-term portfolios, focusing on the goals and guidelines of institutional accounts, including pension plans, corporate treasuries, endowments and public funds. While at Bankers Trust, Karen was a leader in the design and development of a customized client reporting system. Previously, she was the operations manager of a short-term management group at Chemical Bank. Karen is a graduate of Villanova University with a B.A. in economics, and has an M.B.A. in finance from New York University.

19. Fixed Income Investment Management Team Jeff Boundy Portfolio Manager Years of investment experience: 34 Jeff Boundy is Portfolio Manager with the Fixed Income Managed Accounts team, managing the municipal bond sectors, a role he has held since 2004. The strategies include 13 state-specific strategies, 23 state preferred programs as well as a national approach. Jeff has over 31 years of experience in equity and fixed income trading and operations. Since joining ING Investment Management’ predecessor firm in 1996, he has held a variety of trading and operational responsibilities. Previously, he was with Morgan Stanley Asset Management. He received a B.B.A. from Baruch College. Toby Tolino Portfolio Manager Years of investment experience: 12 Toby Tolino is a Portfolio Manager in the Fixed Income Managed Account group with trading and municipal portfolio management responsibilities. Toby joined ING Investment Management in 2000 and has experience in trading, operations and middle office management. In his prior role, Toby managed a team of Senior Portfolio Management Assistants (PMAs) supporting more than ten Portfolio Managers who ran portfolios in all asset classes. He was also responsible for ING Investment Management’s outsourcing relationship for the SMA back office operations. Prior to heading Middle Office, Toby led the NY Fixed Income PMA team and has served in various other operational roles. Toby currently attends CUNY and holds the Series 7 license.

20. Fixed Income Investment Management Team David Handy Credit Analyst Years of investment experience: 6 David Handy joined ING Investment Management in 2010 as a Credit Analyst for the Fixed Income Managed Accounts team. David is responsible for credit monitoring, fundamental analysis and quantitative measurement for investment grade taxable bonds. He also performs risk analytics and portfolio modeling. Previously David was a portfolio analyst at Citi Global Wealth Management in the Strategic Asset Allocation group and was responsible for portfolio modeling and risk analysis. David also worked at the US Department of Treasury for the Trouble Asset Relief Program and also at the Office of Economic Policy. David holds a B.A. in mathematics and economics from Kenyon College and an M.B.A. in quantitative finance from New York University. He has passed the three levels of the CFA exam, is a member of the CFA Institute and the New York Society of Analysts. Rachael Camargo Portfolio Specialist Years of investment experience: 11 Rachael Camargo is a Portfolio Specialist within ING Investment Management’s Multi-Asset Strategies and Solutions team. She is responsible for driving asset growth and retention activities for traditional asset allocation products, portable alpha strategies and customized solutions with ING’s distribution, external parties and key clients. Rachael manages the business and commercial aspects of the investment team in partnership with product management, sales and client service groups. Previously, Rachael was responsible for the firm’s fundamental equity strategies, including Large-Cap Core, 130/30, and sector-specific portfolios such as global natural resources, technology and financials. Her experience also extends to closed-end funds from concept through launch. Rachael joined ING Investment Management in 2001. Prior to joining ING, she worked at Grey Global Group and Wechsler Ross & Partners. She received a B.F.A. from Carnegie Mellon University and an M.B.A. from New York University’s Stern School of Business. Additionally, she holds the Series 7 and 66 licenses with FINRA.

21. ING Investment Management U.S.

22. Disclosures This information is proprietary and cannot be reproduced or distributed. Certain information may be received from sources ING Investment Management (“ING IM”) considers reliable; ING IM does not represent that such information is accurate or complete. Certain statements contained herein may constitute "projections," "forecasts" and other "forward-looking statements" which do not reflect actual results and are based primarily upon applying retroactively a hypothetical set of assumptions to certain historical financial data. Actual results, performance or events may differ materially from those in such statements due to, among other things, (i) general economic conditions, in particular economic conditions in ING IM's core markets, (ii) performance of financial markets, including emerging markets, (iii) the frequency and severity of insured loss events, (iv) mortality and morbidity levels and trends, (v) persistency levels, (vi) interest rate levels, (vii) currency exchange rates (viii) general competitive factors, (ix) changes in laws and regulations, (x) changes in the policies of governments and/or regulatory authorities, (xi) conclusions with regard to purchase accounting assumptions and methodologies, (xii) ING IM's ability to achieve projected operational synergies. Any opinions, projections, forecasts and forward looking statements presented herein are valid only as of the date of this document and are subject to change. Nothing contained herein should be construed as (i) an offer to buy any security or (ii) a recommendation as to the advisability of investing in, purchasing or selling any security. ING IM assumes no obligation to update any forward-looking information.