Exhibit 16(5)
[ING LOGO]
AMERICAS
US Legal Services
J. Neil McMurdie
Senior Counsel
(860) 580-2824
Fax: (860) 580-4844
Neil.McMurdie@us.ing.com
April 2, 2012
Securities and Exchange Commission
100 F. Street, NE
Washington, DC 20549
Attention: Filing Desk
Re: ING Life Insurance and Annuity Company
Prospectus Title: Guaranteed Accumulation Account
Registration Statement on Form S-3
File No.:
Dear Ladies and Gentlemen:
As Counsel to ING Life Insurance and Annuity Company, a Connecticut life insurance company (the
“Company”), I have represented the Company in connection with the Guaranteed Accumulation Account
(the “Account”) available under certain variable annuity contracts and the S-3 Registration Statement
relating to such Account.
In connection with this opinion, I have reviewed the Registration Statement on Form S-3 relating to such
Account, including the prospectus, and relevant proceedings of the Board of Directors.
Based upon this review, and assuming the securities represented by the Company are issued in accordance
with the provisions of the prospectus, I am of the opinion that the securities, when sold, will have been
legally issued, and will constitute a legal and binding obligation of the Company.
I further consent to the use of this opinion as an exhibit to the Registration Statement.
Very truly yours,
/s/ J. Neil McMurdie
J. Neil McMurdie
Senior Counsel
One Orange Way	ING North America Insurance Corporation
Windsor, CT 06095