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February 25, 1994
Securities and Exchange Commission
450 5th Street, NW
Attn: Filing Desk, Stop 1-4
Washington, D.C. 20549-1004
RE: Rule 24f-2 Notice for
IDS Life Account SBS
SEC File No. 33-40779/812-7731
Gentlemen:
[i] In accordance with the provisions of Rule 24f-2, IDS Life
Account SBS hereby files its Rule 24f-2 Notice for the fiscal year
ended December 31, 1993 ("Fiscal Year").
[ii] Amount of securities registered other
than under 24f-2 which were unsold at
the beginning of the fiscal year $0
[iii] Amount of securities registered during
the fiscal year other than under 24f-2 $0
[iv] Amount of securities sold during the
fiscal year $98,039,000*
[v] Amount of securities sold pursuant to 24f-2 $98,039,000
[vi] Fee $98,039,000 X 0.00034483 equals $33,806.79
* Sales of $117,723,000 minus redemptions of $19,684,000
Enclosed please find an opinion of counsel.
If there are any questions, please contact the undersigned.
Very truly yours,
IDS LIFE ACCOUNT SBS
Mary Ellyn Minenko
Counsel
(612) 671-3678
MEM/JDS/smb
Enclosures<PAGE>
EXHIBIT INDEX
(b) (10) OPINION OF COUNSEL
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February 25, 1994
IDS Life Insurance Company
IDS Tower 10
Minneapolis, MN 55440-0010
Gentlemen:
Reference is made to the Registration Statement of IDS Life Account SBS
on Form N-4 (File No. 33-40779) under the Securities Act of 1933 which
became effective October 16, 1991 registering an indefinite amount of
securities pursuant to Rule 24f-2 adopted under The Investment Company
Act of 1940. In connection with the Rule 24f-2 Notice for the fiscal
year ended December 31, 1992, I have made such examination of matter of
fact and law as I have deemed appropriate, and am of the opinion that:
1) During the entire period covered by the Rule 24f-2 Notice,
IDS Life Account SBS, was a validly created and existing
separate account of IDS Life Insurance Company duly
authorized, as a unit investment trust, to issue and sell the
securities registered, and
2) The securities issued, being variable annuity contracts,
were legally issued and non-assessable and require no
further payment by the purchaser.
I hereby consent that the foregoing opinion may be used in connection
with the Rule 24f-2 Notice.
Sincerely,
Mary Ellyn Minenko
Attorney at Law
(612) 671-3678
MEM/JDS/smb
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