SecProbe.io

June 18 , 2013

Via E -mail
Bridget M. Healy
Executive Vice President and
Chief Legal Officer
ING U.S., Inc.
230 Park Avenue
New York, NY 10169

Re: ING U.S., Inc.
  Registration Statement on Form S -4
Filed  June 10 , 2013
  File No.  333-189199

Dear Ms. Healy :

We have limited our review of your registra tion statement to the issue we have addressed
in the comment below.

General

1. We note tha t you are registering new  notes in reliance on our position enunciated in
Exxon Capital Holdings Corp., SEC No -Action Letter (April 13, 1988).  See also  Morgan
Stanley & Co. Inc., SEC No -Action Letter (June 5, 1991) and Shearman & Sterling, SEC
No-Action Letter (July 2, 1993). Acc ordingly, please provide us with a supplemental
letter stating that you are registering the exchange offer in reliance on our position
contained in these letters and include the representations contained in the Morgan Stanley
and Shearman & Sterling no -action letters .

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since th e company and its management are in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Notwithstanding our comment , in the event you request acceleration of t he effective date
of the pending registration statement please provide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose  the Commission from taking any action with respect
to the filing;

Bridget M. Healy
ING U.S., Inc.
June 18 , 2013
Page 2

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the ade quacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the Unite d States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effective date of the
registration statement.

Please contact Austin Stephenson at (202) 551 -3192 , Bryan Pitko at (202) 551 -3203 , or
me at (202) 551 -3715 with any  questions.

Sincerely,

 /s/ Bryan J. Pitko  for

 Jeffrey P. Riedler
Assistant Director

cc: Via E -mail
Robert G. DeLaMater , Esq.
Sullivan & Cromwell LLP