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<TYPE>EX-99.77B
<SEQUENCE>2
<FILENAME>ex99_77b.txt
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                                                                   Exhibit 77(b)


             Report of Independent Registered Public Accounting Firm

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

In planning and performing our audit of the financial statements of ING Prime
Rate Trust as of and for the year ended February, 28 2006, in accordance with
the standards of the Public Company Accounting Oversight Board (United States),
we considered its internal control over financial reporting, including control
activities for safeguarding securities, as a basis for designing our auditing
procedures for the purpose of expressing our opinion on the financial statements
and to comply with the requirements of Form N-SAR, but not for the purpose of
expressing an opinion on the effectiveness of ING Prime Rate Trust's internal
control over financial reporting.
Accordingly, we express no such opinion.

The management of ING Prime Rate Trust is responsible for establishing and
maintaining effective internal control over financial reporting. In fulfilling
this responsibility, estimates and judgments by management are required to
assess the expected benefits and related costs of controls. A company's internal
control over financial reporting is a process designed to provide reasonable
assurance regarding the reliability of financial reporting and the preparation
of financial statements for external purposes in accordance with U.S. generally
accepted accounting principles. Such internal control includes policies and
procedures that provide reasonable assurance regarding prevention or timely
detection of unauthorized acquisition, use or disposition of a company's assets
that could have a material effect on the financial statements. Because of its
inherent limitations, internal control over financial reporting may not prevent
or detect misstatements. Also, projections of any evaluation of effectiveness to
future periods are subject to the risk that controls may become inadequate
because of changes in conditions, or that the degree of compliance with the
policies or procedures may deteriorate.

A control deficiency exists when the design or operation of a control does not
allow management or employees, in the normal course of performing their assigned
functions, to prevent or detect misstatements on a timely basis. A significant
deficiency is a control deficiency, or combination of control deficiencies, that
adversely affects the company's ability to initiate, authorize, record, process
or report external financial data reliably in accordance with U.S. generally
accepted accounting principles such that there is more than a remote likelihood
that a misstatement of the company's annual or interim financial statements that
is more than inconsequential will not be prevented or detected. 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.


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Our consideration of ING Prime Rate Trust's internal control over financial
reporting was for the limited purpose described in the first paragraph and would
not necessarily disclose all deficiencies in internal control that might be
significant deficiencies or material weaknesses under standards established by
the Public Company Accounting Oversight Board (United States). However, we noted
no deficiencies in ING Prime Rate Trust's internal control over financial
reporting and its operation, including controls for safeguarding securities,
that we consider to be a material weakness as defined above as of February 28,
2006.

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.




Boston, Massachusetts
April 21, 2006






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