Ing Investors Trust CORRESPCorrespondence with SEC

Ms. Melissa McDonough, CPA

U.S. Securities and Exchange Commission

August 21, 2023

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Response: The Funds will update disclosure responsive to Item 11(b) of Form N-CSR to reflect the new term "period" in the Funds' next N-CSR filings, and the Funds confirm that there have been no changes in internal controls related to Fund reporting.

4.Comment: The Staff noted that Item 4(e)(2) of Form N-CSR requires disclosure regarding situations where the pre-approval requirement of Rule 2-01 of Regulation S-X was waived with respect to specific services versus which services were obtained and requested that the Funds update relevant disclosure to reflect when the pre-approval requirement was waived.

Response: The Funds confirm that there were no instances of the pre-approval requirement being waived in the period by the reports. In addition, the Funds confirm disclosure will be updated in the Funds' next N-CSR filings, pursuant to paragraph (c)(7)(i)(C) of Rule 2-01 of Regulation S-X, to clarify that the pre-approval requirement was not waived with respect to any services, as applicable.

5.Comment: The Staff noted that Voya Global Bond Fund, Voya Global High Dividend Low Volatility Fund, and Voya Multi-Manager International Factors Fund each include a line item entitled "Payment by affiliate" with additional footnote disclosure for Voya Multi-Manager International Factors Fund stating the payments impacted total returns. The Staff noted, however, that rather than including a dollar amount, the line item instead includes a dash. The Staff requested that the Funds clarify the value of the payments.

Response: With respect to Voya Global Bond Fund and Voya Global High Dividend Low Volatility Fund, each Fund confirms that there have been no payments made by an affiliate during the five fiscal years presented in the financial highlights. With respect to Voya Multi-Manager International Factors Fund, the Fund confirms the payment by an affiliate resulted in a per share impact of less than $0.00. The Funds also note a standardized financial highlights template, which includes a column for "Payment by affiliate," is utilized across all Voya mutual funds within shareholder reports and statutory prospectuses.

6.Comment: The Staff noted that Voya Global Bond Fund, Voya Global High Dividend Low Volatility Fund, and Voya Global Perspectives® Fund include disclosure stating that the Investment Adviser has agreed to limit certain expenses and that the Investment Adviser may later recoup fees waived and/or other expenses reimbursed by the Investment Adviser. The Staff noted further that there is no disclosure of Commitments and Contingent Liabilities on the balance sheet as required by Article 6-04.15 of Regulation S-X and requested that the Funds explain supplementally why such disclosure is not included.

Response: No contingent liabilities related to the recoupment of class specific fees previously waived and/or other expenses previously reimbursed by the Investment Adviser were recorded on the balance sheets of the Funds as of the fiscal year end because the criteria to record such liability was not met as of that date. In making such assessment, the Funds relied on Financial Accounting Standards Board ("FASB"), Accounting Standards Codification ("ASC") 946-20-25-4 (Expense Limitation Agreements) and its references to FASB Concept Statement No. 6, Elements of Financial Statements, and the criteria in paragraph 450-20-25-2.

7.Comment: The Staff noted that Voya Global Bond Fund and VY® Invesco Equity and Income Portfolio have consistently reported high portfolio turnover rates in the financial highlights. The Staff requested that the Funds specify whether active and frequent trading are part of the Funds' investment strategies and state why a corresponding risk about portfolio turnover is not included in the Funds' prospectuses.

Ms. Melissa McDonough, CPA

U.S. Securities and Exchange Commission

August 21, 2023

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Response: The Funds appreciate the Staff's comment; however, the Funds do not believe disclosure in the "Principal Investment Strategies" section of the Funds' prospectuses is necessary because frequent and active trading is not, in reference to Instruction 1 to Item 9(b)(1) of Form N-1A, a specific "policy, practice or technique used by [a] Fund to achieve its investment objectives."

In addition, the Funds believe that any risks related to portfolio turnover are sufficiently disclosed in response to Items 3 and 16(e) of Form N-1A. For example, the summary prospectus for each Fund states that the Fund "pays transaction costs, such as commissions, when it buys and sells securities (or 'turns over' its portfolio). A higher portfolio turnover rate may indicate higher transaction costs. These costs, which are not reflected in Annual [Fund/Portfolio] Operating Expenses or in the Expense Example, affect the [Fund's/Portfolio's] performance." Accordingly, the Funds do not believe it is necessary to include additional disclosure risk disclosure in the "Principal Risks" section.

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Should you have any questions or comments regarding this letter, please contact Todd Modic at (480) 477- 2190, Dorothy Roman at (480) 477-2669, Jennifer Kasperkowiak at (480) 477-2171, or the undersigned at

(212)309-6566.

Regards,

/s/ Nicholas C.D. Ward Nicholas C.D. Ward Counsel

Voya Investment Management

cc:Huey P. Falgout, Jr., Esq. Voya Investments, LLC

Elizabeth J. Reza, Esq.

Ropes & Gray LLP

Jessica Reece, Esq.

Ropes & Gray LLP

Jeremy Smith, Esq.

Ropes & Gray LLP