SBL FUND
24F-2NT, 1997-02-28
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<PAGE>


                     U.S. SECURITIES AND EXCHANGE COMMISSION
                             Washington, D.C. 20549

                                   FORM 24F-2

                        ANNUAL NOTICE OF SECURITIES SOLD
                             PURSUANT TO RULE 24F-2

             READ INSTRUCTIONS AT END OF FORM BEFORE PREPARING FORM.
                             PLEASE PRINT OR TYPE.


  1.  Name and address of issuer:

           SBL Fund, 700 Harrison, Topeka, Kansas 66636-0001

  2.  Name of each series or class of funds for which this notice is filed:

           Series A

  3.  Investment Company Act File Number:  811-2753
      Securities Act File Number:  2-59353

  4.  Last day of fiscal year for which this notice is filed:

           December 31, 1996

  5.  Check box if this notice is being filed more than 180 days after the close
      of the  issuer's  fiscal year for purposes of  reporting  securities  sold
      after the close of the fiscal year but before  termination of the issuer's
      24f-2 declaration:

                                                                            |_|

  6.  Date of termination of issuer's  declaration  under rule  24f-2(a)(1),  if
      applicable (see Instruction A.6):

  7.  Number and amount of securities of the same class or series which had been
      registered  under the  Securities  Act of 1933 other than pursuant to rule
      24f-2 in a prior fiscal year, but which  remained  unsold at the beginning
      of the fiscal year:

           None.

  8.  Number and amount of  securities  registered  during the fiscal year other
      than pursuant to rule 24f-2:

           None.

  9.  Number and aggregate sale price of securities sold during the fiscal year:

                                0                                            $0

 10.  Number and aggregate sale price of securities  sold during the fiscal year
      in reliance upon registration pursuant to rule 24f-2:

                                0                                            $0

 11.  Number and  aggregate  sale price of  securities  issued during the fiscal
      year in connection  with dividend  reinvestment  plans, if applicable (see
      Instruction B.7):

                                0                                            $0


<PAGE>

                           INVESTMENT COMPANIES-FORMS

 12.  Calculation of registration fee:

      (i)   Aggregate  sale price of  securities  sold during the fiscal year in
            reliance on rule 24f-2 (from Item 10):

                                                                             $0

      (ii)  Aggregate  price  of  shares  issued  in  connection  with  dividend
            reinvestment plans (from Item 11, if applicable):

                                                                            +$0

      (iii) Aggregate price of shares redeemed or repurchased during the fiscal 
            year (if applicable):

                                                                            -$0

      (iv)  Aggregate  price of shares  redeemed or  repurchased  and previously
            applied as a  reduction  to filing  fees  pursuant to rule 24e-2 (if
            applicable):

                                                                            +$0

      (v)   Net aggregate  price of securities sold and issued during the fiscal
            year in reliance on rule 24f-2 [line (i), plus line (ii),  less line
            (iii), plus line (iv)] (if applicable):

                                                                             $0

      (vi)  Multiplier prescribed by Section 6(b) of the  Securities Act of 1933
            or other applicable law or regulation (see instruction C.6):

                                                                       x 1/3300

      (vii) Fee due [line (i) or (line (v)  multiplied  by line  (vi)]:      $0

            SBL Fund serves as the underlying  funding vehicle for variable life
            insurance and variable annuity contracts.  SBL Fund sells its shares
            exclusively to separate  accounts of Security Benefit Life Insurance
            Company and the separate  accounts are registered as unit investment
            trusts.  Accordingly,  the Fund is not  required to include as sales
            those  securities  that are sold to an unmanaged  insurance  company
            separate  account the  interests in which are  registered  under the
            Securities  Act,  and on which  registration  fees have been paid or
            will be paid.

 13.  Check  box  if  fees  are  being  remitted  to  the  Commission's  lockbox
      depository  as  described  in  section  3a of the  Commission's  Rules  of
      Informal and Other Procedures (17 CFR 202.3a)

                                                                            |_|

      Date of  mailing  or wire  transfer  of  filing  fees to the  Commission's
      lockbox depository:


                                   SIGNATURES

This  report has been  signed  below by the  following  persons on behalf of the
issuer and in the capacities and on the dates indicated.

By (Signature and Title)*            AMY J. LEE
                          ---------------------------------
                               Amy J. Lee, Secretary

Date      February 28, 1997
     ----------------------------

  *Please print the name and title of the signing officer below the signature.


<PAGE>


                     U.S. SECURITIES AND EXCHANGE COMMISSION
                             Washington, D.C. 20549

                                   FORM 24F-2

                        ANNUAL NOTICE OF SECURITIES SOLD
                             PURSUANT TO RULE 24F-2

             READ INSTRUCTIONS AT END OF FORM BEFORE PREPARING FORM.
                              PLEASE PRINT OR TYPE.


  1.  Name and address of issuer:

           SBL Fund, 700 Harrison, Topeka, Kansas 66636-0001

  2.  Name of each series or class of funds for which this notice is filed:

           Series B

  3.  Investment Company Act File Number:  811-2753
      Securities Act File Number:  2-59353

  4.  Last day of fiscal year for which this notice is filed:

           December 31, 1996

  5.  Check box if this notice is being filed more than 180 days after the close
      of the  issuer's  fiscal year for purposes of  reporting  securities  sold
      after the close of the fiscal year but before  termination of the issuer's
      24f-2 declaration:

                                                                            |_|

  6.  Date of termination of issuer's  declaration  under rule  24f-2(a)(1),  if
      applicable (see Instruction A.6):

  7.  Number and amount of securities of the same class or series which had been
      registered  under the  Securities  Act of 1933 other than pursuant to rule
      24f-2 in a prior fiscal year, but which  remained  unsold at the beginning
      of the fiscal year:

           None.

  8.  Number and amount of  securities  registered  during the fiscal year other
      than pursuant to rule 24f-2:

           None.

  9.  Number and aggregate sale price of securities sold during the fiscal year:

                                0                                            $0

 10.  Number and aggregate sale price of securities  sold during the fiscal year
      in reliance upon registration pursuant to rule 24f-2:

                                0                                            $0

 11.  Number and  aggregate  sale price of  securities  issued during the fiscal
      year in connection  with dividend  reinvestment  plans, if applicable (see
      Instruction B.7):

                                0                                            $0


<PAGE>

                           INVESTMENT COMPANIES-FORMS

 12.  Calculation of registration fee:

      (i)   Aggregate  sale price of  securities  sold during the fiscal year in
            reliance on rule 24f-2 (from Item 10):

                                                                             $0

      (ii)  Aggregate  price  of  shares  issued  in  connection  with  dividend
            reinvestment plans (from Item 11, if applicable):

                                                                            +$0

      (iii) Aggregate price of shares redeemed or repurchased during the fiscal 
            year (if applicable):

                                                                            -$0

      (iv)  Aggregate  price of shares  redeemed or  repurchased  and previously
            applied as a  reduction  to filing  fees  pursuant to rule 24e-2 (if
            applicable):

                                                                             +0

      (v)   Net aggregate  price of securities sold and issued during the fiscal
            year in reliance on rule 24f-2 [line (i), plus line (ii),  less line
            (iii), plus line (iv)] (if applicable):

                                                                             $0

      (vi)  Multiplier prescribed by Section 6(b) of the  Securities Act of 1933
            or other applicable law or regulation (see instruction C.6):

                                                                       x 1/3300

      (vii) Fee due [line (i) or (line (v)  multiplied  by line  (vi)]:      $0

            SBL Fund serves as the underlying  funding vehicle for variable life
            insurance and variable annuity contracts.  SBL Fund sells its shares
            exclusively to separate  accounts of Security Benefit Life Insurance
            Company and the separate  accounts are registered as unit investment
            trusts.  Accordingly,  the Fund is not  required to include as sales
            those  securities  that are sold to an unmanaged  insurance  company
            separate  account the  interests in which are  registered  under the
            Securities  Act,  and on which  registration  fees have been paid or
            will be paid.

 13.  Check  box  if  fees  are  being  remitted  to  the  Commission's  lockbox
      depository  as  described  in  section  3a of the  Commission's  Rules  of
      Informal and Other Procedures (17 CFR 202.3a)

                                                                            |_|

      Date of  mailing  or wire  transfer  of  filing  fees to the  Commission's
      lockbox depository:


                                   SIGNATURES

This  report has been  signed  below by the  following  persons on behalf of the
issuer and in the capacities and on the dates indicated.

By (Signature and Title)*             AMY J. LEE
                          -----------------------------------
                                Amy J. Lee, Secretary

Date      February 28, 1997
      -------------------------

  *Please print the name and title of the signing officer below the signature.


<PAGE>


                     U.S. SECURITIES AND EXCHANGE COMMISSION
                             Washington, D.C. 20549

                                   FORM 24F-2

                        ANNUAL NOTICE OF SECURITIES SOLD
                             PURSUANT TO RULE 24F-2

             READ INSTRUCTIONS AT END OF FORM BEFORE PREPARING FORM.
                              PLEASE PRINT OR TYPE.


  1.  Name and address of issuer:

           SBL Fund, 700 Harrison, Topeka, Kansas 66636-0001

  2.  Name of each series or class of funds for which this notice is filed:

           Series C

  3.  Investment Company Act File Number:  811-2753
      Securities Act File Number:  2-59353

  4.  Last day of fiscal year for which this notice is filed:

           December 31, 1996

  5.  Check box if this notice is being filed more than 180 days after the close
      of the  issuer's  fiscal year for purposes of  reporting  securities  sold
      after the close of the fiscal year but before  termination of the issuer's
      24f-2 declaration:

                                                                            |_|

  6.  Date of termination of issuer's  declaration  under rule  24f-2(a)(1),  if
      applicable (see Instruction A.6):

  7.  Number and amount of securities of the same class or series which had been
      registered  under the  Securities  Act of 1933 other than pursuant to rule
      24f-2 in a prior fiscal year, but which  remained  unsold at the beginning
      of the fiscal year:

                                   784,158                         $  9,770,611

  8.  Number and amount of  securities  registered  during the fiscal year other
      than pursuant to rule 24f-2:

           None.

  9.  Number and aggregate sale price of securities sold during the fiscal year:

                                0                                            $0

 10.  Number and aggregate sale price of securities  sold during the fiscal year
      in reliance upon registration pursuant to rule 24f-2:

                                0                                            $0

 11.  Number and  aggregate  sale price of  securities  issued during the fiscal
      year in connection  with dividend  reinvestment  plans, if applicable (see
      Instruction B.7):

                                0                                            $0


<PAGE>

                           INVESTMENT COMPANIES-FORMS

 12.  Calculation of registration fee:

      (i)   Aggregate  sale price of  securities  sold during the fiscal year in
            reliance on rule 24f-2 (from Item 10):

                                                                             $0

      (ii)  Aggregate  price  of  shares  issued  in  connection  with  dividend
            reinvestment plans (from Item 11, if applicable):

                                                                            +$0

      (iii) Aggregate price of shares redeemed or repurchased during the fiscal 
            year (if applicable):

                                                                            -$0

      (iv)  Aggregate  price of shares  redeemed or  repurchased  and previously
            applied as a  reduction  to filing  fees  pursuant to rule 24e-2 (if
            applicable):

                                                                            +$0
      (v)   Net aggregate  price of securities sold and issued during the fiscal
            year in reliance on rule 24f-2 [line (i), plus line (ii),  less line
            (iii), plus line (iv)] (if applicable):

                                                                             $0

      (vi)  Multiplier prescribed by Section 6(b) of the  Securities Act of 1933
            or other applicable law or regulation (see instruction C.6):

                                                                       x 1/3300

      (vii) Fee due [line (i) or (line (v)  multiplied  by line  (vi)]:      $0

            SBL Fund serves as the underlying  funding vehicle for variable life
            insurance and variable annuity contracts.  SBL Fund sells its shares
            exclusively to separate  accounts of Security Benefit Life Insurance
            Company and the separate  accounts are registered as unit investment
            trusts.  Accordingly,  the Fund is not  required to include as sales
            those  securities  that are sold to an unmanaged  insurance  company
            separate  account the  interests in which are  registered  under the
            Securities  Act,  and on which  registration  fees have been paid or
            will be paid.

 13.  Check  box  if  fees  are  being  remitted  to  the  Commission's  lockbox
      depository  as  described  in  section  3a of the  Commission's  Rules  of
      Informal and Other Procedures (17 CFR 202.3a)

                                                                            |_|

      Date of  mailing  or wire  transfer  of  filing  fees to the  Commission's
      lockbox depository:


                                   SIGNATURES

This  report has been  signed  below by the  following  persons on behalf of the
issuer and in the capacities and on the dates indicated.

By (Signature and Title)*              AMY J. LEE
                          ------------------------------------
                                 Amy J. Lee, Secretary

Date      February 28, 1997
     --------------------------

  *Please print the name and title of the signing officer below the signature.


<PAGE>


                     U.S. SECURITIES AND EXCHANGE COMMISSION
                             Washington, D.C. 20549

                                   FORM 24F-2

                        ANNUAL NOTICE OF SECURITIES SOLD
                             PURSUANT TO RULE 24F-2

             READ INSTRUCTIONS AT END OF FORM BEFORE PREPARING FORM.
                              PLEASE PRINT OR TYPE.


  1.  Name and address of issuer:

           SBL Fund, 700 Harrison, Topeka, Kansas 66636-0001

  2.  Name of each series or class of funds for which this notice is filed:

           Series D

  3.  Investment Company Act File Number:  811-2753
      Securities Act File Number:  2-59353

  4.  Last day of fiscal year for which this notice is filed:

           December 31, 1996

  5.  Check box if this notice is being filed more than 180 days after the close
      of the  issuer's  fiscal year for purposes of  reporting  securities  sold
      after the close of the fiscal year but before  termination of the issuer's
      24f-2 declaration:

                                                                            |_|

  6.  Date of termination of issuer's  declaration  under rule  24f-2(a)(1),  if
      applicable (see Instruction A.6):

  7.  Number and amount of securities of the same class or series which had been
      registered  under the  Securities  Act of 1933 other than pursuant to rule
      24f-2 in a prior fiscal year, but which  remained  unsold at the beginning
      of the fiscal year:

           None.

  8.  Number and amount of  securities  registered  during the fiscal year other
      than pursuant to rule 24f-2:

           None.

  9.  Number and aggregate sale price of securities sold during the fiscal year:

                                0                                            $0

 10.  Number and aggregate sale price of securities  sold during the fiscal year
      in reliance upon registration pursuant to rule 24f-2:

                                0                                            $0

 11.  Number and  aggregate  sale price of  securities  issued during the fiscal
      year in connection  with dividend  reinvestment  plans, if applicable (see
      Instruction B.7):

                                0                                            $0


<PAGE>

                           INVESTMENT COMPANIES-FORMS

 12.  Calculation of registration fee:

      (i)   Aggregate  sale price of  securities  sold during the fiscal year in
            reliance on rule 24f-2 (from Item 10):

                                                                             $0

      (ii)  Aggregate  price  of  shares  issued  in  connection  with  dividend
            reinvestment plans (from Item 11, if applicable):

                                                                            +$0

      (iii) Aggregate price of shares redeemed or repurchased during the fiscal 
            year (if applicable):

                                                                            -$0

      (iv)  Aggregate  price of shares  redeemed or  repurchased  and previously
            applied as a  reduction  to filing  fees  pursuant to rule 24e-2 (if
            applicable):

                                                                            +$0

      (v)   Net aggregate  price of securities sold and issued during the fiscal
            year in reliance on rule 24f-2 [line (i), plus line (ii),  less line
            (iii), plus line (iv)] (if applicable):

                                                                             $0

      (vi)  Multiplier prescribed by Section 6(b) of the  Securities Act of 1933
            or other applicable law or regulation (see instruction C.6):

                                                                       x 1/3300

      (vii) Fee due [line (i) or (line (v)  multiplied  by line  (vi)]:      $0

            SBL Fund serves as the underlying  funding vehicle for variable life
            insurance and variable annuity contracts.  SBL Fund sells its shares
            exclusively to separate  accounts of Security Benefit Life Insurance
            Company and the separate  accounts are registered as unit investment
            trusts.  Accordingly,  the Fund is not  required to include as sales
            those  securities  that are sold to an unmanaged  insurance  company
            separate  account the  interests in which are  registered  under the
            Securities  Act,  and on which  registration  fees have been paid or
            will be paid.

 13.  Check  box  if  fees  are  being  remitted  to  the  Commission's  lockbox
      depository  as  described  in  section  3a of the  Commission's  Rules  of
      Informal and Other Procedures (17 CFR 202.3a)

                                                                            |_|

      Date of  mailing  or wire  transfer  of  filing  fees to the  Commission's
      lockbox depository:


                                   SIGNATURES

This  report has been  signed  below by the  following  persons on behalf of the
issuer and in the capacities and on the dates indicated.

By (Signature and Title)*             AMY J. LEE
                          ----------------------------------
                                Amy J. Lee, Secretary

Date     February 28, 1997
     --------------------------

  *Please print the name and title of the signing officer below the signature.


<PAGE>


                     U.S. SECURITIES AND EXCHANGE COMMISSION
                             Washington, D.C. 20549

                                   FORM 24F-2

                        ANNUAL NOTICE OF SECURITIES SOLD
                             PURSUANT TO RULE 24F-2

             READ INSTRUCTIONS AT END OF FORM BEFORE PREPARING FORM.
                             PLEASE PRINT OR TYPE.


  1.  Name and address of issuer:

           SBL Fund, 700 Harrison, Topeka, Kansas 66636-0001

  2.  Name of each series or class of funds for which this notice is filed:

           Series E

  3.  Investment Company Act File Number:  811-2753
      Securities Act File Number:  2-59353

  4.  Last day of fiscal year for which this notice is filed:

           December 31, 1996

  5.  Check box if this notice is being filed more than 180 days after the close
      of the  issuer's  fiscal year for purposes of  reporting  securities  sold
      after the close of the fiscal year but before  termination of the issuer's
      24f-2 declaration:

                                                                            |_|

  6.  Date of termination of issuer's  declaration  under rule  24f-2(a)(1),  if
      applicable (see Instruction A.6):

  7.  Number and amount of securities of the same class or series which had been
      registered  under the  Securities  Act of 1933 other than pursuant to rule
      24f-2 in a prior fiscal year, but which  remained  unsold at the beginning
      of the fiscal year:

           None.

  8.  Number and amount of  securities  registered  during the fiscal year other
      than pursuant to rule 24f-2:

           None.

  9.  Number and aggregate sale price of securities sold during the fiscal year:

                                0                                            $0

 10.  Number and aggregate sale price of securities  sold during the fiscal year
      in reliance upon registration pursuant to rule 24f-2:

                                0                                            $0

 11.  Number and  aggregate  sale price of  securities  issued during the fiscal
      year in connection  with dividend  reinvestment  plans, if applicable (see
      Instruction B.7):

                                0                                            $0


<PAGE>

                           INVESTMENT COMPANIES-FORMS


 12.  Calculation of registration fee:

      (i)   Aggregate  sale price of  securities  sold during the fiscal year in
            reliance on rule 24f-2 (from Item 10):

                                                                             $0

      (ii)  Aggregate  price  of  shares  issued  in  connection  with  dividend
            reinvestment plans (from Item 11, if applicable):

                                                                            +$0

      (iii) Aggregate price of shares redeemed or repurchased during the fiscal 
            year (if applicable):

                                                                            -$0

      (iv)  Aggregate  price of shares  redeemed or  repurchased  and previously
            applied as a  reduction  to filing  fees  pursuant to rule 24e-2 (if
            applicable):

                                                                            +$0

      (v)   Net aggregate  price of securities sold and issued during the fiscal
            year in reliance on rule 24f-2 [line (i), plus line (ii),  less line
            (iii), plus line (iv)] (if applicable):

                                                                             $0

      (vi)  Multiplier prescribed by Section 6(b) of the  Securities Act of 1933
            or other applicable law or regulation (see instruction C.6):

                                                                       x 1/3300

      (vii) Fee due [line (i) or (line (v)  multiplied  by line  (vi)]:      $0

            SBL Fund serves as the underlying  funding vehicle for variable life
            insurance and variable annuity contracts.  SBL Fund sells its shares
            exclusively to separate  accounts of Security Benefit Life Insurance
            Company and the separate  accounts are registered as unit investment
            trusts.  Accordingly,  the Fund is not  required to include as sales
            those  securities  that are sold to an unmanaged  insurance  company
            separate  account the  interests in which are  registered  under the
            Securities  Act,  and on which  registration  fees have been paid or
            will be paid.

 13.  Check  box  if  fees  are  being  remitted  to  the  Commission's  lockbox
      depository  as  described  in  section  3a of the  Commission's  Rules  of
      Informal and Other Procedures (17 CFR 202.3a)

                                                                            |_|

      Date of  mailing  or wire  transfer  of  filing  fees to the  Commission's
      lockbox depository:


                                   SIGNATURES

This  report has been  signed  below by the  following  persons on behalf of the
issuer and in the capacities and on the dates indicated.

By (Signature and Title)*               AMY J. LEE
                          -------------------------------------
                                  Amy J. Lee, Secretary

Date     February 28, 1997
     -----------------------------

  *Please print the name and title of the signing officer below the signature.


<PAGE>


                     U.S. SECURITIES AND EXCHANGE COMMISSION
                             Washington, D.C. 20549

                                   FORM 24F-2

                        ANNUAL NOTICE OF SECURITIES SOLD
                             PURSUANT TO RULE 24F-2

             READ INSTRUCTIONS AT END OF FORM BEFORE PREPARING FORM.
                             PLEASE PRINT OR TYPE.


  1.  Name and address of issuer:

           SBL Fund, 700 Harrison, Topeka, Kansas 66636-0001

  2.  Name of each series or class of funds for which this notice is filed:

           Series J

  3.  Investment Company Act File Number:  811-2753
      Securities Act File Number:  2-59353

  4.  Last day of fiscal year for which this notice is filed:

           December 31, 1996

  5.  Check box if this notice is being filed more than 180 days after the close
      of the  issuer's  fiscal year for purposes of  reporting  securities  sold
      after the close of the fiscal year but before  termination of the issuer's
      24f-2 declaration:

                                                                            |_|

  6.  Date of termination of issuer's  declaration  under rule  24f-2(a)(1),  if
      applicable (see Instruction A.6):

  7.  Number and amount of securities of the same class or series which had been
      registered  under the  Securities  Act of 1933 other than pursuant to rule
      24f-2 in a prior fiscal year, but which  remained  unsold at the beginning
      of the fiscal year:

           None.

  8.  Number and amount of  securities  registered  during the fiscal year other
      than pursuant to rule 24f-2:

           None.

  9.  Number and aggregate sale price of securities sold during the fiscal year:

                                0                                            $0

 10.  Number and aggregate sale price of securities  sold during the fiscal year
      in reliance upon registration pursuant to rule 24f-2:

                                0                                            $0

 11.  Number and  aggregate  sale price of  securities  issued during the fiscal
      year in connection  with dividend  reinvestment  plans, if applicable (see
      Instruction B.7):

                                0                                            $0


<PAGE>

                           INVESTMENT COMPANIES-FORMS

 12.  Calculation of registration fee:

      (i)   Aggregate  sale price of  securities  sold during the fiscal year in
            reliance on rule 24f-2 (from Item 10):

                                                                             $0

      (ii)  Aggregate  price  of  shares  issued  in  connection  with  dividend
            reinvestment plans (from Item 11, if applicable):

                                                                            +$0

      (iii) Aggregate price of shares redeemed or repurchased during the fiscal 
            year (if applicable):

                                                                            -$0

      (iv)  Aggregate  price of shares  redeemed or  repurchased  and previously
            applied as a  reduction  to filing  fees  pursuant to rule 24e-2 (if
            applicable):

                                                                            +$0

      (v)   Net aggregate  price of securities sold and issued during the fiscal
            year in reliance on rule 24f-2 [line (i), plus line (ii),  less line
            (iii), plus line (iv)] (if applicable):

                                                                             $0

      (vi)  Multiplier prescribed by Section 6(b) of the  Securities Act of 1933
            or other applicable law or regulation (see instruction C.6):

                                                                       x 1/3300

      (vii) Fee due [line (i) or (line (v)  multiplied  by line  (vi)]:      $0

            SBL Fund serves as the underlying  funding vehicle for variable life
            insurance and variable annuity contracts.  SBL Fund sells its shares
            exclusively to separate  accounts of Security Benefit Life Insurance
            Company and the separate  accounts are registered as unit investment
            trusts.  Accordingly,  the Fund is not  required to include as sales
            those  securities  that are sold to an unmanaged  insurance  company
            separate  account the  interests in which are  registered  under the
            Securities  Act,  and on which  registration  fees have been paid or
            will be paid.

 13.  Check  box  if  fees  are  being  remitted  to  the  Commission's  lockbox
      depository  as  described  in  section  3a of the  Commission's  Rules  of
      Informal and Other Procedures (17 CFR 202.3a)

                                                                            |_|

      Date of  mailing  or wire  transfer  of  filing  fees to the  Commission's
      lockbox depository:


                                   SIGNATURES

This  report has been  signed  below by the  following  persons on behalf of the
issuer and in the capacities and on the dates indicated.

By (Signature and Title)*               AMY J. LEE
                          --------------------------------------
                                  Amy J. Lee, Secretary

Date     February 28, 1997
     --------------------------

  *Please print the name and title of the signing officer below the signature.


<PAGE>


                     U.S. SECURITIES AND EXCHANGE COMMISSION
                             Washington, D.C. 20549

                                   FORM 24F-2

                        ANNUAL NOTICE OF SECURITIES SOLD
                             PURSUANT TO RULE 24F-2

             READ INSTRUCTIONS AT END OF FORM BEFORE PREPARING FORM.
                              PLEASE PRINT OR TYPE.

  1.  Name and address of issuer:

           SBL Fund, 700 Harrison, Topeka, Kansas 66636-0001

  2.  Name of each series or class of funds for which this notice is filed:

           Series K

  3.  Investment Company Act File Number:  811-2753
      Securities Act File Number:  2-59353

  4.  Last day of fiscal year for which this notice is filed:

           December 31, 1996

  5.  Check box if this notice is being filed more than 180 days after the close
      of the  issuer's  fiscal year for purposes of  reporting  securities  sold
      after the close of the fiscal year but before  termination of the issuer's
      24f-2 declaration:

                                                                            |_|

  6.  Date of termination of issuer's  declaration  under rule  24f-2(a)(1),  if
      applicable (see Instruction A.6):

  7.  Number and amount of securities of the same class or series which had been
      registered  under the  Securities  Act of 1933 other than pursuant to rule
      24f-2 in a prior fiscal year, but which  remained  unsold at the beginning
      of the fiscal year:

  8.  Number and amount of  securities  registered  during the fiscal year other
      than pursuant to rule 24f-2:

           None.

  9.  Number and aggregate sale price of securities sold during the fiscal year:

                                0                                            $0

 10.  Number and aggregate sale price of securities  sold during the fiscal year
      in reliance upon registration pursuant to rule 24f-2:

                                0                                            $0

 11.  Number and  aggregate  sale price of  securities  issued during the fiscal
      year in connection  with dividend  reinvestment  plans, if applicable (see
      Instruction B.7):

                                0                                            $0


<PAGE>


                           INVESTMENT COMPANIES-FORMS

 12.  Calculation of registration fee:

      (i)   Aggregate  sale price of  securities  sold during the fiscal year in
            reliance on rule 24f-2 (from Item 10):

                                                                             $0

      (ii)  Aggregate  price  of  shares  issued  in  connection  with  dividend
            reinvestment plans (from Item 11, if applicable):

                                                                            +$0

      (iii) Aggregate price of shares redeemed or repurchased during the fiscal 
            year (if applicable):

                                                                            -$0

      (iv)  Aggregate  price of shares  redeemed or  repurchased  and previously
            applied as a  reduction  to filing  fees  pursuant to rule 24e-2 (if
            applicable):

                                                                            +$0

      (v)   Net aggregate  price of securities sold and issued during the fiscal
            year in reliance on rule 24f-2 [line (i), plus line (ii),  less line
            (iii), plus line (iv)] (if applicable):

                                                                              $

      (vi)  Multiplier prescribed by Section 6(b) of the  Securities Act of 1933
            or other applicable law or regulation (see instruction C.6):

                                                                       x 1/3300

      (vii) Fee due [line (i) or (line (v)  multiplied  by line  (vi)]:      $0

            SBL Fund serves as the underlying  funding vehicle for variable life
            insurance and variable annuity contracts.  SBL Fund sells its shares
            exclusively to separate  accounts of Security Benefit Life Insurance
            Company and the separate  accounts are registered as unit investment
            trusts.  Accordingly,  the Fund is not  required to include as sales
            those  securities  that are sold to an unmanaged  insurance  company
            separate  account the  interests in which are  registered  under the
            Securities  Act,  and on which  registration  fees have been paid or
            will be paid.

 13.  Check  box  if  fees  are  being  remitted  to  the  Commission's  lockbox
      depository  as  described  in  section  3a of the  Commission's  Rules  of
      Informal and Other Procedures (17 CFR 202.3a)

                                                                            |X|

      Date of  mailing  or wire  transfer  of  filing  fees to the  Commission's
      lockbox depository:


                                   SIGNATURES

This  report has been  signed  below by the  following  persons on behalf of the
issuer and in the capacities and on the dates indicated.

By (Signature and Title)*                AMY J. LEE
                          ----------------------------------------
                                   Amy J. Lee, Secretary

Date      February 28, 1997
     ----------------------------

  *Please print the name and title of the signing officer below the signature.


<PAGE>


                     U.S. SECURITIES AND EXCHANGE COMMISSION
                             Washington, D.C. 20549

                                   FORM 24F-2

                        ANNUAL NOTICE OF SECURITIES SOLD
                             PURSUANT TO RULE 24F-2

             READ INSTRUCTIONS AT END OF FORM BEFORE PREPARING FORM.
                             PLEASE PRINT OR TYPE.


  1.  Name and address of issuer:

           SBL Fund, 700 Harrison, Topeka, Kansas 66636-0001

  2.  Name of each series or class of funds for which this notice is filed:

           Series M

  3.  Investment Company Act File Number:  811-2753
      Securities Act File Number:  2-59353

  4.  Last day of fiscal year for which this notice is filed:

           December 31, 1996

  5.  Check box if this notice is being filed more than 180 days after the close
      of the  issuer's  fiscal year for purposes of  reporting  securities  sold
      after the close of the fiscal year but before  termination of the issuer's
      24f-2 declaration:

                                                                            |_|

  6.  Date of termination of issuer's  declaration  under rule  24f-2(a)(1),  if
      applicable (see Instruction A.6):

  7.  Number and amount of securities of the same class or series which had been
      registered  under the  Securities  Act of 1933 other than pursuant to rule
      24f-2 in a prior fiscal year, but which  remained  unsold at the beginning
      of the fiscal year:

           None.

  8.  Number and amount of  securities  registered  during the fiscal year other
      than pursuant to rule 24f-2:

           None.

  9.  Number and aggregate sale price of securities sold during the fiscal year:

                                0                                            $0

 10.  Number and aggregate sale price of securities  sold during the fiscal year
      in reliance upon registration pursuant to rule 24f-2:

                                0                                            $0

 11.  Number and  aggregate  sale price of  securities  issued during the fiscal
      year in connection  with dividend  reinvestment  plans, if applicable (see
      Instruction B.7):

                                0                                            $0


<PAGE>


                           INVESTMENT COMPANIES-FORMS

 12.  Calculation of registration fee:

      (i)   Aggregate  sale price of  securities  sold during the fiscal year in
            reliance on rule 24f-2 (from Item 10):

                                                                             $0

      (ii)  Aggregate  price  of  shares  issued  in  connection  with  dividend
            reinvestment plans (from Item 11, if applicable):

                                                                            +$0

      (iii) Aggregate price of shares redeemed or repurchased during the fiscal 
            year (if applicable):

                                                                            -$0

      (iv)  Aggregate  price of shares  redeemed or  repurchased  and previously
            applied as a  reduction  to filing  fees  pursuant to rule 24e-2 (if
            applicable):

                                                                            +$0

      (v)   Net aggregate  price of securities sold and issued during the fiscal
            year in reliance on rule 24f-2 [line (i), plus line (ii),  less line
            (iii), plus line (iv)] (if applicable):

                                                                            $0

      (vi)  Multiplier prescribed by Section 6(b) of the  Securities Act of 1933
            or other applicable law or regulation (see instruction C.6):

                                                                       x 1/3300

      (vii) Fee due [line (i) or (line (v)  multiplied  by line  (vi)]:      $0

            SBL Fund serves as the underlying  funding vehicle for variable life
            insurance and variable annuity contracts.  SBL Fund sells its shares
            exclusively to separate  accounts of Security Benefit Life Insurance
            Company and the separate  accounts are registered as unit investment
            trusts.  Accordingly,  the Fund is not  required to include as sales
            those  securities  that are sold to an unmanaged  insurance  company
            separate  account the  interests in which are  registered  under the
            Securities  Act,  and on which  registration  fees have been paid or
            will be paid.

 13.  Check  box  if  fees  are  being  remitted  to  the  Commission's  lockbox
      depository  as  described  in  section  3a of the  Commission's  Rules  of
      Informal and Other Procedures (17 CFR 202.3a)

                                                                            |_|

      Date of  mailing  or wire  transfer  of  filing  fees to the  Commission's
      lockbox depository:


                                   SIGNATURES

This  report has been  signed  below by the  following  persons on behalf of the
issuer and in the capacities and on the dates indicated.

By (Signature and Title)*                 AMY J. LEE
                          ------------------------------------------
                                    Amy J. Lee, Secretary

Date      February 28, 1997
      --------------------------

  *Please print the name and title of the signing officer below the signature.


<PAGE>


                     U.S. SECURITIES AND EXCHANGE COMMISSION
                             Washington, D.C. 20549

                                   FORM 24F-2

                        ANNUAL NOTICE OF SECURITIES SOLD
                             PURSUANT TO RULE 24F-2

             READ INSTRUCTIONS AT END OF FORM BEFORE PREPARING FORM.
                             PLEASE PRINT OR TYPE.


  1.  Name and address of issuer:

           SBL Fund, 700 Harrison, Topeka, Kansas 66636-0001

  2.  Name of each series or class of funds for which this notice is filed:

           Series N

  3.  Investment Company Act File Number:  811-2753
      Securities Act File Number:  2-59353

  4.  Last day of fiscal year for which this notice is filed:

           December 31, 1996

  5.  Check box if this notice is being filed more than 180 days after the close
      of the  issuer's  fiscal year for purposes of  reporting  securities  sold
      after the close of the fiscal year but before  termination of the issuer's
      24f-2 declaration:

                                                                            |_|

  6.  Date of termination of issuer's  declaration  under rule  24f-2(a)(1),  if
      applicable (see Instruction A.6):

  7.  Number and amount of securities of the same class or series which had been
      registered  under the  Securities  Act of 1933 other than pursuant to rule
      24f-2 in a prior fiscal year, but which  remained  unsold at the beginning
      of the fiscal year:

           None.

  8.  Number and amount of  securities  registered  during the fiscal year other
      than pursuant to rule 24f-2:

           None.

  9.  Number and aggregate sale price of securities sold during the fiscal year:

                                0                                            $0

 10.  Number and aggregate sale price of securities  sold during the fiscal year
      in reliance upon registration pursuant to rule 24f-2:

                                0                                            $0

 11.  Number and  aggregate  sale price of  securities  issued during the fiscal
      year in connection  with dividend  reinvestment  plans, if applicable (see
      Instruction B.7):

                                0                                            $0


<PAGE>


                           INVESTMENT COMPANIES-FORMS

 12.  Calculation of registration fee:

      (i)   Aggregate  sale price of  securities  sold during the fiscal year in
            reliance on rule 24f-2 (from Item 10):

                                                                             $0

      (ii)  Aggregate  price  of  shares  issued  in  connection  with  dividend
            reinvestment plans (from Item 11, if applicable):

                                                                            +$0

      (iii) Aggregate price of shares redeemed or repurchased during the fiscal 
            year (if applicable):

                                                                            -$0

      (iv)  Aggregate  price of shares  redeemed or  repurchased  and previously
            applied as a  reduction  to filing  fees  pursuant to rule 24e-2 (if
            applicable):

                                                                            +$0

      (v)   Net aggregate  price of securities sold and issued during the fiscal
            year in reliance on rule 24f-2 [line (i), plus line (ii),  less line
            (iii), plus line (iv)] (if applicable):

                                                                             $0

      (vi)  Multiplier prescribed by Section 6(b) of the  Securities Act of 1933
            or other applicable law or regulation (see instruction C.6):

                                                                      x  1/3300

      (vii) Fee due [line (i) or (line (v)  multiplied  by line  (vi)]:      $0

            SBL Fund serves as the underlying  funding vehicle for variable life
            insurance and variable annuity contracts.  SBL Fund sells its shares
            exclusively to separate  accounts of Security Benefit Life Insurance
            Company and the separate  accounts are registered as unit investment
            trusts.  Accordingly,  the Fund is not  required to include as sales
            those  securities  that are sold to an unmanaged  insurance  company
            separate  account the  interests in which are  registered  under the
            Securities  Act,  and on which  registration  fees have been paid or
            will be paid.

 13.  Check  box  if  fees  are  being  remitted  to  the  Commission's  lockbox
      depository  as  described  in  section  3a of the  Commission's  Rules  of
      Informal and Other Procedures (17 CFR 202.3a)

                                                                            |_|

      Date of  mailing  or wire  transfer  of  filing  fees to the  Commission's
      lockbox depository:


                                   SIGNATURES

This  report has been  signed  below by the  following  persons on behalf of the
issuer and in the capacities and on the dates indicated.

By (Signature and Title)*                 AMY J. LEE
                           ----------------------------------------
                                    Amy J. Lee, Secretary

Date     February 28, 1997
     ------------------------

  *Please print the name and title of the signing officer below the signature.


<PAGE>


                     U.S. SECURITIES AND EXCHANGE COMMISSION
                             Washington, D.C. 20549

                                   FORM 24F-2

                        ANNUAL NOTICE OF SECURITIES SOLD
                             PURSUANT TO RULE 24F-2

             READ INSTRUCTIONS AT END OF FORM BEFORE PREPARING FORM.
                             PLEASE PRINT OR TYPE.


  1.  Name and address of issuer:

           SBL Fund, 700 Harrison, Topeka, Kansas 66636-0001

  2.  Name of each series or class of funds for which this notice is filed:

           Series O

  3.  Investment Company Act File Number:  811-2753
      Securities Act File Number:  2-59353

  4.  Last day of fiscal year for which this notice is filed:

           December 31, 1996

  5.  Check box if this notice is being filed more than 180 days after the close
      of the  issuer's  fiscal year for purposes of  reporting  securities  sold
      after the close of the fiscal year but before  termination of the issuer's
      24f-2 declaration:

                                                                            |_|

  6.  Date of termination of issuer's  declaration  under rule  24f-2(a)(1),  if
      applicable (see Instruction A.6):

  7.  Number and amount of securities of the same class or series which had been
      registered  under the  Securities  Act of 1933 other than pursuant to rule
      24f-2 in a prior fiscal year, but which  remained  unsold at the beginning
      of the fiscal year:

           None.

  8.  Number and amount of  securities  registered  during the fiscal year other
      than pursuant to rule 24f-2:

           None.

  9.  Number and aggregate sale price of securities sold during the fiscal year:

                                0                                            $0

 10.  Number and aggregate sale price of securities  sold during the fiscal year
      in reliance upon registration pursuant to rule 24f-2:

                                0                                            $0

 11.  Number and  aggregate  sale price of  securities  issued during the fiscal
      year in connection  with dividend  reinvestment  plans, if applicable (see
      Instruction B.7):

                                0                                            $0


<PAGE>

                           INVESTMENT COMPANIES-FORMS

 12.  Calculation of registration fee:

      (i)   Aggregate  sale price of  securities  sold during the fiscal year in
            reliance on rule 24f-2 (from Item 10):

                                                                             $0

      (ii)  Aggregate  price  of  shares  issued  in  connection  with  dividend
            reinvestment plans (from Item 11, if applicable):

                                                                             $0

      (iii) Aggregate price of shares redeemed or repurchased during the fiscal 
            year (if applicable):

                                                                            -$0

      (iv)  Aggregate  price of shares  redeemed or  repurchased  and previously
            applied as a  reduction  to filing  fees  pursuant to rule 24e-2 (if
            applicable):

                                                                            +$0

      (v)   Net aggregate  price of securities sold and issued during the fiscal
            year in reliance on rule 24f-2 [line (i), plus line (ii),  less line
            (iii), plus line (iv)] (if applicable):

                                                                             $0

      (vi)  Multiplier prescribed by Section 6(b) of the  Securities Act of 1933
            or other applicable law or regulation (see instruction C.6):

                                                                       x 1/3300

      (vii) Fee due [line (i) or (line (v)  multiplied  by line  (vi)]:     $0

            SBL Fund serves as the underlying  funding vehicle for variable life
            insurance and variable annuity contracts.  SBL Fund sells its shares
            exclusively to separate  accounts of Security Benefit Life Insurance
            Company and the separate  accounts are registered as unit investment
            trusts.  Accordingly,  the Fund is not  required to include as sales
            those  securities  that are sold to an unmanaged  insurance  company
            separate  account the  interests in which are  registered  under the
            Securities  Act,  and on which  registration  fees have been paid or
            will be paid.

 13.  Check  box  if  fees  are  being  remitted  to  the  Commission's  lockbox
      depository  as  described  in  section  3a of the  Commission's  Rules  of
      Informal and Other Procedures (17 CFR 202.3a)

                                                                            |_|

      Date of  mailing  or wire  transfer  of  filing  fees to the  Commission's
      lockbox depository:


                                   SIGNATURES

This  report has been  signed  below by the  following  persons on behalf of the
issuer and in the capacities and on the dates indicated.

By (Signature and Title)*              AMY J. LEE
                          ------------------------------------
                                 Amy J. Lee, Secretary

Date     February 28, 1997
     ------------------------

  *Please print the name and title of the signing officer below the signature.


<PAGE>


                     U.S. SECURITIES AND EXCHANGE COMMISSION
                             Washington, D.C. 20549

                                   FORM 24F-2

                        ANNUAL NOTICE OF SECURITIES SOLD
                             PURSUANT TO RULE 24F-2

             READ INSTRUCTIONS AT END OF FORM BEFORE PREPARING FORM.
                             PLEASE PRINT OR TYPE.


  1.  Name and address of issuer:

           SBL Fund, 700 Harrison, Topeka, Kansas 66636-0001

  2.  Name of each series or class of funds for which this notice is filed:

           Series S

  3.  Investment Company Act File Number:  811-2753
      Securities Act File Number:  2-59353

  4.  Last day of fiscal year for which this notice is filed:

           December 31, 1996

  5.  Check box if this notice is being filed more than 180 days after the close
      of the  issuer's  fiscal year for purposes of  reporting  securities  sold
      after the close of the fiscal year but before  termination of the issuer's
      24f-2 declaration:

                                                                            |_|

  6.  Date of termination of issuer's  declaration  under rule  24f-2(a)(1),  if
      applicable (see Instruction A.6):

  7.  Number and amount of securities of the same class or series which had been
      registered  under the  Securities  Act of 1933 other than pursuant to rule
      24f-2 in a prior fiscal year, but which  remained  unsold at the beginning
      of the fiscal year:

           None.

  8.  Number and amount of  securities  registered  during the fiscal year other
      than pursuant to rule 24f-2:

           None.

  9.  Number and aggregate sale price of securities sold during the fiscal year:

                                0                                            $0

 10.  Number and aggregate sale price of securities  sold during the fiscal year
      in reliance upon registration pursuant to rule 24f-2:

                                0                                            $0

 11.  Number and  aggregate  sale price of  securities  issued during the fiscal
      year in connection  with dividend  reinvestment  plans, if applicable (see
      Instruction B.7):

                                0                                            $0


<PAGE>

                           INVESTMENT COMPANIES-FORMS

 12.  Calculation of registration fee:

      (i)   Aggregate  sale price of  securities  sold during the fiscal year in
            reliance on rule 24f-2 (from Item 10):

                                                                             $0

      (ii)  Aggregate  price  of  shares  issued  in  connection  with  dividend
            reinvestment plans (from Item 11, if applicable):

                                                                            +$0

      (iii) Aggregate price of shares redeemed or repurchased during the fiscal 
            year (if applicable):

                                                                            -$0

      (iv)  Aggregate  price of shares  redeemed or  repurchased  and previously
            applied as a  reduction  to filing  fees  pursuant to rule 24e-2 (if
            applicable):

                                                                            +$0

      (v)   Net aggregate  price of securities sold and issued during the fiscal
            year in reliance on rule 24f-2 [line (i), plus line (ii),  less line
            (iii), plus line (iv)] (if applicable):

                                                                             $0

      (vi)  Multiplier prescribed by Section 6(b) of the  Securities Act of 1933
            or other applicable law or regulation (see instruction C.6):

                                                                       x 1/3300

      (vii) Fee due [line (i) or (line (v)  multiplied  by line  (vi)]:      $0

            SBL Fund serves as the underlying  funding vehicle for variable life
            insurance and variable annuity contracts.  SBL Fund sells its shares
            exclusively to separate  accounts of Security Benefit Life Insurance
            Company and the separate  accounts are registered as unit investment
            trusts.  Accordingly,  the Fund is not  required to include as sales
            those  securities  that are sold to an unmanaged  insurance  company
            separate  account the  interests in which are  registered  under the
            Securities  Act,  and on which  registration  fees have been paid or
            will be paid.

 13.  Check  box  if  fees  are  being  remitted  to  the  Commission's  lockbox
      depository  as  described  in  section  3a of the  Commission's  Rules  of
      Informal and Other Procedures (17 CFR 202.3a)

                                                                            |_|

      Date of  mailing  or wire  transfer  of  filing  fees to the  Commission's
      lockbox depository:


                                   SIGNATURES

This  report has been  signed  below by the  following  persons on behalf of the
issuer and in the capacities and on the dates indicated.

By (Signature and Title)*                AMY J. LEE
                           --------------------------------------
                                   Amy J. Lee, Secretary

Date     February 28, 1997
     --------------------------

  *Please print the name and title of the signing officer below the signature.



<PAGE>


                     U.S. SECURITIES AND EXCHANGE COMMISSION
                             Washington, D.C. 20549

                                   FORM 24F-2

                        ANNUAL NOTICE OF SECURITIES SOLD
                             PURSUANT TO RULE 24F-2

             READ INSTRUCTIONS AT END OF FORM BEFORE PREPARING FORM.
                             PLEASE PRINT OR TYPE.


  1.  Name and address of issuer:

           SBL Fund, 700 Harrison, Topeka, Kansas 66636-0001

  2.  Name of each series or class of funds for which this notice is filed:

           Series P

  3.  Investment Company Act File Number:  811-2753
      Securities Act File Number:  2-59353

  4.  Last day of fiscal year for which this notice is filed:

           December 31, 1996

  5.  Check box if this notice is being filed more than 180 days after the close
      of the  issuer's  fiscal year for purposes of  reporting  securities  sold
      after the close of the fiscal year but before  termination of the issuer's
      24f-2 declaration:

                                                                            |_|

  6.  Date of termination of issuer's  declaration  under rule  24f-2(a)(1),  if
      applicable (see Instruction A.6):

  7.  Number and amount of securities of the same class or series which had been
      registered  under the  Securities  Act of 1933 other than pursuant to rule
      24f-2 in a prior fiscal year, but which  remained  unsold at the beginning
      of the fiscal year:

           None.

  8.  Number and amount of  securities  registered  during the fiscal year other
      than pursuant to rule 24f-2:

           None.

  9.  Number and aggregate sale price of securities sold during the fiscal year:

                                166,667                              $2,500,000

 10.  Number and aggregate sale price of securities  sold during the fiscal year
      in reliance upon registration pursuant to rule 24f-2:

                                166,667                              $2,500,000

 11.  Number and  aggregate  sale price of  securities  issued during the fiscal
      year in connection  with dividend  reinvestment  plans, if applicable (see
      Instruction B.7):

                                    -0-                              $        0


<PAGE>

                           INVESTMENT COMPANIES-FORMS

 12.  Calculation of registration fee:

      (i)   Aggregate  sale price of  securities  sold during the fiscal year in
            reliance on rule 24f-2 (from Item 10):

                                                                     $2,500,000

      (ii)  Aggregate  price  of  shares  issued  in  connection  with  dividend
            reinvestment plans (from Item 11, if applicable):

                                                                    +$        0

      (iii) Aggregate price of shares redeemed or repurchased during the fiscal
            year (if applicable):

                                                                    -$        0

      (iv)  Aggregate  price of shares  redeemed or  repurchased  and previously
            applied as a  reduction  to filing  fees  pursuant to rule 24e-2 (if
            applicable):

                                                                    +$        0

      (v)   Net aggregate  price of securities sold and issued during the fiscal
            year in reliance on rule 24f-2 [line (i), plus line (ii),  less line
            (iii), plus line (iv)] (if applicable):

                                                                     $2,500,000

      (vi)  Multiplier prescribed by Section 6(b) of the  Securities Act of 1933
            or other applicable law or regulation (see instruction C.6):

                                                                       x 1/3300

      (vii) Fee due [line (i) or (line (v) multiplied by line (vi)]:    $757.58

            SBL Fund serves as the underlying  funding vehicle for variable life
            insurance and variable annuity contracts.  SBL Fund sells its shares
            exclusively to separate  accounts of Security Benefit Life Insurance
            Company and the separate  accounts are registered as unit investment
            trusts. A $2,500,000  direct investment was made to SBL Fund, Series
            P, upon inception of the fund,  August 5, 1996. A $757.58 fee is due
            on the direct investment.

 13.  Check  box  if  fees  are  being  remitted  to  the  Commission's  lockbox
      depository  as  described  in  section  3a of the  Commission's  Rules  of
      Informal and Other Procedures (17 CFR 202.3a)

                                                                            |X|

      Date of  mailing  or wire  transfer  of  filing  fees to the  Commission's
      lockbox depository:

      February 25, 1997


                                   SIGNATURES

This  report has been  signed  below by the  following  persons on behalf of the
issuer and in the capacities and on the dates indicated.

By (Signature and Title)*              AMY J. LEE
                          -----------------------------------
                                 Amy J. Lee, Secretary

Date     February 28, 1997
      ------------------------

  *Please print the name and title of the signing officer below the signature.




<PAGE>

                                                                       Exhibit 1
                                                                       ---------
[SBG LOGO]
- --------------------------------------------------------------------------------
Security Benefit Life Insurance Company                700 SW Harrison St.
Security Benefit Group, Inc.                           Topeka, Kansas 66636-0001
Security Distributors, Inc.                            (913) 295-3000
Security Management Company


February 28, 1997

SBL Fund
700 Harrison Street
Topeka, KS 66636-0001

Dear Sir/Madam:

I refer to the Rule  24f-2  Notice for File No.  2-59353  of SBL Fund,  a Kansas
corporation,  hereinafter  referred  to as the  "Company,"  being filed with the
Securities  and  Exchange  Commission  for the  purpose of  reporting  under the
Securities  Act of 1933 166,667 shares of Series P shares of the $1.00 par value
capital  stock of the Company  sold during the fiscal  year ended  December  31,
1996.

I have  examined  the Articles of  Incorporation  and the bylaws of the Company,
minutes of the applicable meetings of the Board of Directors and stockholders of
the Company,  and other  corporate  records,  applicable  certificates of public
officials, and other documents I have deemed relevant.

Based upon the foregoing, it is my opinion that:

(1)   The Company is duly  organized,  existing and in good  standing  under the
      laws of the State of Kansas.

(2)   The Company has  authorization  to sell an indefinite  number of shares of
      capital  stock  of the  par  value  of  $1.00  per  share  pursuant  to an
      indefinite registration of such shares made effective February 5, 1982.

(3)   All necessary  corporate  actions have been taken to authorize the sale by
      the  Company,   for  the  consideration  set  forth  in  the  registration
      statement,  of the 166,667 shares  (aggregate sale price of $2,500,000) of
      capital  stock of the Company,  and, upon the sale by the Company of those
      shares, they were duly issued, fully paid and nonassessable.

I hereby  consent to the  inclusion  in said Rule 24f-2  Notice of my  foregoing
opinion filed as Exhibit 1 thereto.

Very truly yours,

AMY J. LEE

Amy J. Lee
Vice President, Associate General
Counsel and Assistant Secretary
Security Benefit Life Insurance Company




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