EFTA Document EFTA01365366

INDENTURE, dated as of June 22, 2011 between: ING IM CLO 2011-1, LTD., an exempted company incorporated with limited liability and existing under the laws of the Cayman Islands (the "Issuer") and ING IM CLO 2011-1 LLC, a limited liability company organized and existing under the laws of the State of Delaware (the "Co-Issue?' and, together with the Issuer, the "Co-Issuers") and THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION, a national banking association, as trustee (herei