SecProbe.io

October 23, 2013

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

Re: ING U.S., Inc.
  Registration Statement on Form S-4
Filed  October 11, 2013
  File No.  333-191709

Dear Ms. Healy :

We have limited our review of your registration statement to those issues we have
addressed in our comment.

General

1. We note that you are registering the 5.7% Senior Notes due 2043 and related guarantees
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 & Sterlin g, SEC No -Action Letter (July 2, 1993).
Accordingly, 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 M organ 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 applic able Securities  Act rules require.   Since the 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 s, in the event you request acceleration of the 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, declar e 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.
October 23, 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 com pany from its full responsibility for
the adequacy 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 u nder the federal
securities laws of the United 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 registra tion statement.  Please allow
adequate time  for us to review any amendment prior to the requested effective date of the
registration statement.

Please contact Matthew Jones  at (202) 551 -3786, Bryan Pitko at (202) 551 -3203,  or me at
(202) 551 -3715 with any other questions.

Sincerely,

 /s/ Bryan J. Pitko for

Jeffrey P. Riedler
Assistant Director