BANNER LIFE VARIABLE ANNUITY ACCOUNT
24F-2NT, 1997-06-30
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June 27, 1997

United States Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549

Re:  Rule 24f-2 Notice for Banner Life Variable Annuity Account of 
     Banner Life Insurance Company
     Registration No: 33-31308

Ladies and Gentlemen:

Pursuant to Rule 24f-2 under the Investment Company Act of 1940, as amended,
you are hereby notified that:

     1.)  the Banner Life Variable Annuity Account fiscal year for which
          this Notice is filed is the calendar year ended December 31, 1996;

     2.)  the amount of Banner Life Variable Annuity Account securities
          which had been registered under the Securities Act of 1933 other
          than pursuant to Rule 24f-2 but which remained unsold at the
          beginning of such fiscal year was: $-0-;

     3.)  the amount of Banner Life Variable Annuity Account securities
          registered during such fiscal year other than pursuant to Rule
          24f-2 was: $-0-;

     4.)  the amount of Banner Life Variable Annuity Account securities sold
          during such fiscal year was: $145,543; and

     5.)  the amount of Banner Life Variable Annuity Account securities sold
          during such fiscal year in reliance upon registration pursuant to
          Rule 24f-2 was: $145,543.

Attached hereto is an opinion of counsel as required.  The filing fee of
$50.19 has been electronically submitted for payment based upon aggregate
premiums of $145,543.

Sincerely,

/s/Mark A. Canter
Mark A. Canter
Vice President, Secretary
  and General Counsel

cc:  Frederick Bellamy, Esq.

June 27, 1997

United States Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549

Re:  Rule 24f-2 Notice for Banner Life Variable Annuity Account of 
     Banner Life Insurance Company
     Registration No: 33-31308

Ladies and Gentlemen:

It is my opinion that the securities issued in accordance with the captioned
filing and which this Notice makes definite in number were legally issued and
non-assessable.  They were not fully paid, however, since the variable annuity
contracts issued in connection with the Banner Life Variable Annuity Account
contemplate the payment of additional premiums.

Very truly yours,

/s/Mark A. Canter
Mark A. Canter
Vice President, Secretary 
  and General Counsel


cc:  Frederick R. Bellamy, Esq.












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