|EXHIBIT
  31.1
|--------------



|CERTIFICATION
|-------------



|I, Karen Czizik, certify
      that:
|------------------------------------

|1. | I have reviewed this report on Form 10-K and all reports
      on Form 8-K and Form 10-D required to be filed in respect of the period
      covered by this report on Form 10-K of ING USA Global Funding Trust 3
      (the "Periodic Reports");                                                                                                                                                                                                                                                                                                                                                                      
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|  
|2. | Based on my knowledge, the Periodic Reports, taken as a
      whole, do not contain any untrue statement of a material fact or omit to
      state a material fact necessary in order to make the statements made, in
      light of the circumstances under which such statements were made, not
      misleading with respect to the period covered by this report;                                                                                                                                                                                                                                                   
|  
|3. | Based on my knowledge, all of the distribution,
      servicing and other information required to be provided under Form 8-K and
      Form 10-D for the period covered by this report is included in the
      Periodic Reports;                                                                                                                                                                                                                                                                                                                                                                                       
|  
|4. | Based on my knowledge and the servicer compliance
      statement required in this report under Item 1123 of Regulation AB, and
      except as disclosed in the Periodic Reports, the servicer has fulfilled
      its obligations under the servicing agreement in all material
      respects;                                                                                                                                                                                                                                                                                                                       
|  
|5. | All of the reports on assessment of compliance with
      servicing criteria for asset-backed securities and their related
      attestation reports on assessment of compliance with servicing criteria
      for asset- backed securities required to be included in this report in
      accordance with Item 1122 of Regulation AB and Exchange Act Rule 13a-18
      and 15d-18 have been included as an exhibit to this report, except as
      otherwise disclosed in this report. Any material instances of
      noncompliance described in such reports have been disclosed in this report
      on Form 10-K.
|  

In giving the certification above, I have
reasonably relied on information provided to me by the following unaffiliated
parties: Ernst & Young LLP and Citibank, N.A.

Date: April 2,
      2007
    
    By:/s/
      Karen CzizikName: Karen
      CzizikTitle: Vice
      President


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