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August 30, 2000
SM&R Investments, Inc.
2450 South Shore Boulevard, Suite 400
League City, Texas 77573
RE: SM&R Investments, Inc. (the "Fund") Post-Effective Amendment
No. 17 under the Securities Act of 1933 (the "33 Act") and to
the Investment Company Act of 1940 (the "40 Act") to Form N-1A
Registration Statement No. 33-44021
Gentlemen:
We have assisted you in preparing the above referenced post-effective
amendments to your '33 Act and '40 Act Registration Statements referenced above.
In connection therewith, we have examined the Company's Articles of
Incorporation and such other corporate records, prospectuses and other material
we deemed appropriate. On the basis of such examination, we are of the opinion
that the Company's shares, when sold, will be legally issued, fully paid and
non-assessable. We, of course, assume that the Company will not sell more than
the 6,000,000,000 shares authorized by its Articles of Incorporation, and that
all sales will be for full value received at the time of sale.
We consent to the attachment of this opinion to and its used in
connection with the above referenced post-effective amendments.
Yours very truly,
/s/ Jerry L. Adams
Jerry L. Adams
