EFTA Document EFTA01422826

Attached please find an electronic copy of the offering memorandum (the "Offering Memorandum"), dated June 15, 2011, relating to the Securities of ING IM CLO 2011-1, Ltd. (the "Issuer") and ING IM CLO 2011-1 LLC (the "Co-Issuer" and, together with the Issuer, the "CoIssuers"). The Offering Memorandum is highly confidential and does not constitute an offer to any person other than the recipient or to the public generally to subscribe for or otherwise acquire Securities. DISTRIBUTION OF