SBL VARIABLE ANNUITY ACCOUNT XIV
N-4, EX-99.9, 2000-07-11
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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


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