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June 28, 2000
Security Benefit Life Insurance Company
700 SW Harrison Street
Topeka, KS 66636-0001
Re: SBL Variable Annuity Account XIV
Dear Sir/Madam:
This letter is with reference to the Registration Statement of SBL Variable
Annuity Account XIV of which Security Benefit Life Insurance Company
(hereinafter "SBL") is the Depositor. Said Registration Statement is being filed
with the Securities and Exchange Commission for the purpose of registering the
variable annuity contract issued by SBL and the interests in SBL Variable
Annuity Account XIV under such variable annuity contract which will be sold
pursuant to an indefinite registration.
I have examined the Articles of Incorporation and Bylaws of SBL, minutes of the
meetings of its Board of Directors and other records, and pertinent provisions
of the Kansas insurance laws, together with applicable certificates of public
officials and other documents which I have deemed relevant. Based on the
foregoing, it is my opinion that:
1. SBL is duly organized and validly existing as a stock life insurance company
under the laws of Kansas.
2. SBL Variable Annuity Account XIV has been validly created as a Separate
Account in accordance with the pertinent provisions of the insurance laws of
Kansas.
3. SBL has the power, and has validly and legally exercised it, to create and
issue the variable annuity contract which is administered within and by
means of SBL Variable Annuity Account XIV.
4. The amount of the variable annuity contract to be sold pursuant to the
indefinite registration, when issued, will represent binding obligations of
SBL in accordance with their terms providing said contract was issued for
the considerations set forth therein and evidenced by appropriate policies
and certificates.
I hereby consent to the inclusion in the Registration Statement of my foregoing
opinion.
Respectfully submitted,
AMY J. LEE
Amy J. Lee
Associate General Counsel and Vice President
Security Benefit Life Insurance Company