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[LETTERHEAD]
November 27, 2000
EquiTrust Money Market Fund, Inc.
5400 University Avenue
West Des Moines, Iowa 50266-5997
Ladies and Gentlemen:
Reference is made to Post-Effective Amendment No. 21 to the Registration
Statement on Form N-1A under the Securities Act of 1933 being filed by EquiTrust
Money Market Fund, Inc., a Maryland Corporation (the "Fund"), in connection with
the public offering from time to time of any or all of those 500 million
authorized shares of common stock, par value $.001 per share ("Shares").
We are counsel to the Fund, and in such capacity are familiar with the
Fund's organization and have counseled the Fund regarding various legal matters.
We have examined such Fund records and other documents and certificates as we
have considered necessary or appropriate for the purposes of this opinion. In
our examination of such materials, we have assumed the genuineness of all
signatures and the conformity to original documents of all copies submitted to
us.
Based upon the foregoing, and assuming that the Fund's Articles of
Incorporation filed November 5, 1980, as amended by the the Articles of
Amendment filed February 24, 1981, Articles of Restatement filed February 24,
1981, and the Articles of Amendment filed May 1, 1998 (the "Articles"), and the
Fund's Bylaws adopted November 6, 1980, as amended August 13, 1986, August 12,
1987, and August 15, 1996, are presently in full force and effect and have not
been amended in any respect except as provided in the above-referenced
documents; and that the resolutions adopted by the Board of Directors of the
Fund on November 6, 1980, January 11, 1981, August 15, 1996 and January 1, 1998
relating to organizational matters, securities matters and the issuance of
shares are presently in full force and effect and have not been amended in any
respect, we advise you and opine that (a) the Fund is a validly existing
corporation under the laws of the State of Maryland and is authorized to issue
the Shares; and (b) presently and upon such further issuance of the Shares in
accordance with the Fund's Articles and the receipt by the Fund of a purchase
price not less than the net asset value per Share, and when the pertinent
provisions of the Securities Act of 1933 and such "blue-sky" and securities laws
as may be applicable have been complied with, assuming that the Fund continues
to validly exist as provided in (a) above and assuming that the number of Shares
issued by the Fund does not exceed the number of Shares authorized, the Shares
are and will be legally
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VEDDER PRICE
EquiTrust Money Market Fund, Inc.
November 27, 2000
Page 2
issued and outstanding, fully paid and nonassessable.
This opinion is solely for the benefit of the Fund, the Fund's Board of
Directors and the Fund's officers and may not be relied upon by any other person
without our prior written consent. We hereby consent to the use of this opinion
in connection with said Post-Effective Amendment.
Very truly yours,
/s/ Vedder, Price, Kaufman & Kammholz
VEDDER, PRICE, KAUFMAN & KAMMHOLZ
COK/DAS
