PFL VARIABLE ANNUITY FUND II
N-30D, 2000-03-13
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                    [PFL Life Insurance Company Letterhead]



March 13, 2000



VIA EDGAR

- --------------------------------------

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549

Re:  PFL Variable Annuity Fund II
     File No. 811- 02411, CIK 0000078011
     Rule 30b2-1 Filing

Commissioners:

As required by Rule 30d-2 under the Investment Company Act of 1940, as amended
(the "Act"), PFL Variable Annuity Fund II, a unit investment trust registered
under the Act, recently mailed to its contract owners the annual report for the
underlying management investment company Lexington Growth & Income Fund, Inc.
This filing constitutes the filing of that report as required by Rule 30b2-1
under the Act.

Pursuant to Rule 30d-1 under the Act, on February 28, 2000, Lexington Growth &
Income Fund, Inc. filed its annual report with the Commission via EDGAR (CIK:
59146).  To the extent necessary, that filing is incorporated herein by
reference.

Very truly yours,

PFL Life Insurance Company

/s/ Frank A. Camp

Frank A. Camp
Division General Counsel
Financial Markets Division


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