<DOCUMENT>
<TYPE>EX-99.77(B)
<SEQUENCE>2
<FILENAME>e500503_ex99-77b.txt
<DESCRIPTION>REPORT OF PUBLIC ACCOUNTING FIRM
<TEXT>

                                                                   Exhibit 77(b)

             Report of Independent Registered Public Accounting Firm

To the Shareholders and Board of Trustees
ING Prime Rate Trust:

In planning and performing our audit of the financial statements of ING Prime
Rate Trust for the year ended February 28, 2005, we considered its internal
control, including control activities for safeguarding securities, in order to
determine our auditing procedures for the purpose of expressing our opinion on
the financial statements and to comply with the requirements of Form N-SAR, not
to provide assurance on internal control.

The management of ING Prime Rate Trust is responsible for establishing and
maintaining internal control. In fulfilling this responsibility, estimates and
judgments by management are required to assess the expected benefits and related
costs of controls. Generally, controls that are relevant to an audit pertain to
the entity's objective of preparing financial statements for external purposes
that are fairly presented in conformity with accounting principles generally
accepted in the United States of America. Those controls include the
safeguarding of assets against unauthorized acquisition, use, or disposition.

Because of inherent limitations in internal control, error or fraud may occur
and not be detected. Also, projection of any evaluation of internal control to
future periods is subject to the risk that it may become inadequate because of
changes in conditions or that the effectiveness of the design and operation may
deteriorate.

Our consideration of internal control would not necessarily disclose all matters
in internal control that might be material weaknesses under the standards of the
Public Company Accounting Oversight Board (United States). A material weakness
is a significant deficiency, or combination of significant deficiencies, that
results in more than a remote likelihood that a material misstatement of the
annual or interim financial statements will not be prevented or detected.
However, we noted no matters involving internal control and its operation,
including controls for safeguarding securities, that we consider to be material
weaknesses as defined above as of February 28, 2005.

This report is intended solely for the information and use of management and the
Board of Trustees of ING Prime Rate Trust and the Securities and Exchange
Commission and is not intended to be and should not be used by anyone other than
these specified parties.


/s/ KPMG

Los Angeles, California
April 15, 2005
</TEXT>
</DOCUMENT>
