SECURITY EQUITY FUND
24F-2NT, 1996-11-26
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                     U.S. SECURITIES AND EXCHANGE COMMISSION
                             Washington, D.C. 20549

                                   FORM 24F-2

                        ANNUAL NOTICE OF SECURITIES SOLD
                             PURSUANT TO RULE 24F-2

             READ INSTRUCTIONS AT END OF FORM BEFORE PREPARING FORM.
                              PLEASE PRINT OR TYPE.

 1.  Name and address of issuer:

          Security Equity Fund, 700 Harrison, Topeka, Kansas 66636-0001

 2.  Name of each series or class of funds for which this notice is filed:

          Equity Series, Class A

 3.  Investment Company Act File Number:  811-1136
     Securities Act File Number:  2-19458

 4.  Last day of fiscal year for which this notice is filed:

          September 30, 1996

 5.  Check box if this  notice is being filed more than 180 days after the close
     of the issuer's fiscal year for purposes of reporting securities sold after
     the close of the fiscal year but before  termination  of the issuer's 24f-2
     declaration:                                                            |_|

 6.  Date of  termination of issuer's  declaration  under rule  24f-2(a)(1),  if
     applicable (see Instruction A.6):

 7.  Number and amount of  securities of the same class or series which had been
     registered  under the  Securities  Act of 1933 other than  pursuant to rule
     24f-2 in a prior fiscal year, but which remained unsold at the beginning of
     the fiscal year:

                                 1,318,829                          $  8,004,080

 8.  Number and amount of  securities  registered  during the fiscal  year other
     than pursuant to rule 24f-2:

          None

 9.  Number and aggregate sale price of securities sold during the fiscal year:

                                43,657,565                          $299,520,899

10.  Number and aggregate  sale price of securities  sold during the fiscal year
     in reliance upon registration pursuant to rule 24f-2:

                                42,338,736                          $291,516,819

11.  Number and aggregate sale price of securities issued during the fiscal year
     in  connection  with  dividend   reinvestment  plans,  if  applicable  (see
     Instruction B.7):

                                 5,483,525                          $ 34,973,081

12.  Calculation of registration fee:

     (i)    Aggregate  sale price of  securities  sold during the fiscal year in
            reliance on rule 24f-2 (from Item 10):

                                                                    $291,516,819

     (ii)   Aggregate  price  of  shares  issued  in  connection  with  dividend
            reinvestment plans (from Item 11, if applicable):

                                                                   +$ 34,973,081

<PAGE>

                           INVESTMENT COMPANIES-FORMS

12.  Calculation of registration fee (continued):

     (iii)  Aggregate price of shares redeemed or repurchased  during the fiscal
            year (if applicable):

                                                                   -$273,412,317

     (iv)   Aggregate  price of shares  redeemed or  repurchased  and previously
            applied as a  reduction  to filing  fees  pursuant to rule 24e-2 (if
            applicable):

                                                                   +$          0

     (v)    Net aggregate  price of securities sold and issued during the fiscal
            year in reliance on rule 24f-2 [line (i), plus line (ii),  less line
            (iii), plus line (iv)] (if applicable):

                                                                   +$ 53,077,583

     (vi)   Multiplier  prescribed by Section 6(b) of the Securities Act of 1933
            or other applicable law or regulation (see instruction C.6):

                                                                   x      1/3300

     (vii)  Fee due [line (i) or (line (v) multiplied by line (vi)]:

                                                                    $  16,084.12

13.  Check box if fees are being remitted to the Commission's lockbox depository
     as described in section 3a of the Commission's  Rules of Informal and Other
     Procedures (17 CFR 202.3a)

                                                                             |X|

     Date of mailing or wire transfer of filing fees to the Commission's lockbox
     depository:

          November 26, 1996

                                   SIGNATURES

This  report has been  signed  below by the  following  persons on behalf of the
issuer and in the capacities and on the dates indicated.

By (Signature and Title)*                AMY J. LEE
                          ----------------------------------------
                                   Amy J. Lee, Secretary

Date       November 26, 1996
     -----------------------------

  *Please print the name and title of the signing officer below the signature.

<PAGE>

                     U.S. SECURITIES AND EXCHANGE COMMISSION
                             Washington, D.C. 20549

                                   FORM 24F-2

                        ANNUAL NOTICE OF SECURITIES SOLD
                             PURSUANT TO RULE 24F-2

             READ INSTRUCTIONS AT END OF FORM BEFORE PREPARING FORM.
                              PLEASE PRINT OR TYPE.

 1.  Name and address of issuer:

          Security Equity Fund, 700 Harrison, Topeka, Kansas 66636-0001

 2.  Name of each series or class of funds for which this notice is filed:

          Equity Series, Class B

 3.  Investment Company Act File Number: 811-1136
     Securities Act File Number:  2-19458

 4.  Last day of fiscal year for which this notice is filed:

          September 30, 1996

 5.  Check box if this  notice is being filed more than 180 days after the close
     of the issuer's fiscal year for purposes of reporting securities sold after
     the close of the fiscal year but before  termination  of the issuer's 24f-2
     declaration:                                                            |_|

 6.  Date of  termination of issuer's  declaration  under rule  24f-2(a)(1),  if
     applicable (see Instruction A.6):

 7.  Number and amount of  securities of the same class or series which had been
     registered  under the  Securities  Act of 1933 other than  pursuant to rule
     24f-2 in a prior fiscal year, but which remained unsold at the beginning of
     the fiscal year:

          None

 8.  Number and amount of  securities  registered  during the fiscal  year other
     than pursuant to rule 24f-2:

          None

 9.  Number and aggregate sale price of securities sold during the fiscal year:

                                13,771,902                           $93,534,094

10.  Number and aggregate  sale price of securities  sold during the fiscal year
     in reliance upon registration pursuant to rule 24f-2:

                                13,771,902                           $93,534,094

11.  Number and aggregate sale price of securities issued during the fiscal year
     in  connection  with  dividend   reinvestment  plans,  if  applicable  (see
     Instruction B.7):

                                   300,151                           $ 1,882,247

12.  Calculation of registration fee:

     (i)    Aggregate  sale price of  securities  sold during the fiscal year in
            reliance on rule 24f-2 (from Item 10):

                                                                     $93,534,094

     (ii)   Aggregate  price  of  shares  issued  in  connection  with  dividend
            reinvestment plans (from Item 11, if applicable):

                                                                     $ 1,882,247

<PAGE>

                           INVESTMENT COMPANIES-FORMS

12.  Calculation of registration fee (continued):

     (iii)  Aggregate price of shares redeemed or repurchased  during the fiscal
            year (if applicable):

                                                                    -$79,755,552

     (iv)   Aggregate  price of shares  redeemed or  repurchased  and previously
            applied as a  reduction  to filing  fees  pursuant to rule 24e-2 (if
            applicable):

                                                                    +$         0

     (v)    Net aggregate  price of securities sold and issued during the fiscal
            year in reliance on rule 24f-2 [line (i), plus line (ii),  less line
            (iii), plus line (iv)] (if applicable):

                                                                     $15,660,789

     (vi)   Multiplier  prescribed by Section 6(b) of the Securities Act of 1933
            or other applicable law or regulation (see instruction C.6):

                                                                    x     1/3300

     (vii)  Fee due [line (i) or (line (v) multiplied by line (vi)]:

                                                                     $  4,745.69

13.  Check box if fees are being remitted to the Commission's lockbox depository
     as described in section 3a of the Commission's  Rules of Informal and Other
     Procedures (17 CFR 202.3a)

                                                                             |X|

     Date of mailing or wire transfer of filing fees to the Commission's lockbox
     depository:

          November 26, 1996

                                   SIGNATURES

This  report has been  signed  below by the  following  persons on behalf of the
issuer and in the capacities and on the dates indicated.

By (Signature and Title)*                AMY J. LEE
                          ----------------------------------------
                                   Amy J. Lee, Secretary

Date       November 26, 1996
     -----------------------------

  *Please print the name and title of the signing officer below the signature.

<PAGE>

                     U.S. SECURITIES AND EXCHANGE COMMISSION
                             Washington, D.C. 20549

                                   FORM 24F-2

                        ANNUAL NOTICE OF SECURITIES SOLD
                             PURSUANT TO RULE 24F-2

             READ INSTRUCTIONS AT END OF FORM BEFORE PREPARING FORM.
                              PLEASE PRINT OR TYPE.

 1.  Name and address of issuer:

          Security Equity Fund, 700 Harrison, Topeka, Kansas 66636-0001

 2.  Name of each series or class of funds for which this notice is filed:

          Global Series, Class A

 3.  Investment Company Act File Number: 811-1136
     Securities Act File Number:  2-19458

 4.  Last day of fiscal year for which this notice is filed:

          September 30, 1996

 5.  Check box if this  notice is being filed more than 180 days after the close
     of the issuer's fiscal year for purposes of reporting securities sold after
     the close of the fiscal year but before  termination  of the issuer's 24f-2
     declaration:                                                            |_|

 6.  Date of  termination of issuer's  declaration  under rule  24f-2(a)(1),  if
     applicable (see Instruction A.6):

 7.  Number and amount of  securities of the same class or series which had been
     registered  under the  Securities  Act of 1933 other than  pursuant to rule
     24f-2 in a prior fiscal year, but which remained unsold at the beginning of
     the fiscal year:

          None

 8.  Number and amount of  securities  registered  during the fiscal  year other
     than pursuant to rule 24f-2:

          None

 9.  Number and aggregate sale price of securities sold during the fiscal year:

                                   491,586                            $5,778,490

10.  Number and aggregate  sale price of securities  sold during the fiscal year
     in reliance upon registration pursuant to rule 24f-2:

                                   491,586                            $5,778,490

11.  Number and aggregate sale price of securities issued during the fiscal year
     in  connection  with  dividend   reinvestment  plans,  if  applicable  (see
     Instruction B.7):

                                    52,399                            $  570,969

12.  Calculation of registration fee:

     (i)    Aggregate  sale price of  securities  sold during the fiscal year in
            reliance on rule 24f-2 (from Item 10):

                                                                      $5,778,490

<PAGE>

                           INVESTMENT COMPANIES-FORMS

12.  Calculation of registration fee (continued):

     (ii)   Aggregate  price  of  shares  issued  in  connection  with  dividend
            reinvestment plans (from Item 11, if applicable):

                                                                     +$  570,969

     (iii)  Aggregate price of shares redeemed or repurchased  during the fiscal
            year (if applicable):

                                                                     -$5,192,505

     (iv)   Aggregate  price of shares  redeemed or  repurchased  and previously
            applied as a  reduction  to filing  fees  pursuant to rule 24e-2 (if
            applicable):

                                                                     +$        0

     (v)    Net aggregate  price of securities sold and issued during the fiscal
            year in reliance on rule 24f-2 [line (i), plus line (ii),  less line
            (iii), plus line (iv)] (if applicable):

                                                                      $1,156,954

     (vi)   Multiplier  prescribed by Section 6(b) of the Securities Act of 1933
            or other applicable law or regulation (see instruction C.6):

                                                                     x    1/3300

     (vii)  Fee due [line (i) or (line (v) multiplied by line (vi)]:

                                                                      $   350.59

13.  Check box if fees are being remitted to the Commission's lockbox depository
     as described in section 3a of the Commission's  Rules of Informal and Other
     Procedures (17 CFR 202.3a)

                                                                             |X|

     Date of mailing or wire transfer of filing fees to the Commission's lockbox
     depository:

          November 26, 1996

                                   SIGNATURES

This  report has been  signed  below by the  following  persons on behalf of the
issuer and in the capacities and on the dates indicated.

By (Signature and Title)*                AMY J. LEE
                          ----------------------------------------
                                   Amy J. Lee, Secretary

Date       November 26, 1996
     -----------------------------

  *Please print the name and title of the signing officer below the signature.

<PAGE>

                     U.S. SECURITIES AND EXCHANGE COMMISSION
                             Washington, D.C. 20549

                                   FORM 24F-2

                        ANNUAL NOTICE OF SECURITIES SOLD
                             PURSUANT TO RULE 24F-2

             READ INSTRUCTIONS AT END OF FORM BEFORE PREPARING FORM.
                              PLEASE PRINT OR TYPE.

 1.  Name and address of issuer:

          Security Equity Fund, 700 Harrison, Topeka, Kansas 66636-0001

 2.  Name of each series or class of funds for which this notice is filed:

          Global Series, Class B

 3.  Investment Company Act File Number: 811-1136
     Securities Act File Number:  2-19458

 4.  Last day of fiscal year for which this notice is filed:

          September 30, 1996

 5.  Check box if this  notice is being filed more than 180 days after the close
     of the issuer's fiscal year for purposes of reporting securities sold after
     the close of the fiscal year but before  termination  of the issuer's 24f-2
     declaration:                                                            |_|

 6.  Date of  termination of issuer's  declaration  under rule  24f-2(a)(1),  if
     applicable (see Instruction A.6):

 7.  Number and amount of  securities of the same class or series which had been
     registered  under the  Securities  Act of 1933 other than  pursuant to rule
     24f-2 in a prior fiscal year, but which remained unsold at the beginning of
     the fiscal year:

          None

 8.  Number and amount of  securities  registered  during the fiscal  year other
     than pursuant to rule 24f-2:

          None

 9.  Number and aggregate sale price of securities sold during the fiscal year:

                                   186,645                            $2,179,465

10.  Number and aggregate  sale price of securities  sold during the fiscal year
     in reliance upon registration pursuant to rule 24f-2:

                                   186,645                            $2,179,465

11.  Number and aggregate sale price of securities issued during the fiscal year
     in  connection  with  dividend   reinvestment  plans,  if  applicable  (see
     Instruction B.7):

                                    13,842                            $  149,212

12.  Calculation of registration fee:

     (i)    Aggregate  sale price of  securities  sold during the fiscal year in
            reliance on rule 24f-2 (from Item 10):

                                                                      $2,179,465

     (ii)   Aggregate  price  of  shares  issued  in  connection  with  dividend
            reinvestment plans (from Item 11, if applicable):

                                                                     +$  149,212

<PAGE>

                           INVESTMENT COMPANIES-FORMS

12.  Calculation of registration fee (continued):

     (iii)  Aggregate price of shares redeemed or repurchased  during the fiscal
            year (if applicable):

                                                                     -$1,236,321

     (iv)   Aggregate  price of shares  redeemed or  repurchased  and previously
            applied as a  reduction  to filing  fees  pursuant to rule 24e-2 (if
            applicable):

                                                                     +$        0

     (v)    Net aggregate  price of securities sold and issued during the fiscal
            year in reliance on rule 24f-2 [line (i), plus line (ii),  less line
            (iii), plus line (iv)] (if applicable):

                                                                      $1,092,356

     (vi)   Multiplier  prescribed by Section 6(b) of the Securities Act of 1933
            or other applicable law or regulation (see instruction C.6):

                                                                     x    1/3300

     (vii)  Fee due [line (i) or (line (v) multiplied by line (vi)]:

                                                                      $   331.02

13.  Check box if fees are being remitted to the Commission's lockbox depository
     as described in section 3a of the Commission's  Rules of Informal and Other
     Procedures (17 CFR 202.3a)

                                                                             |X|

     Date of mailing or wire transfer of filing fees to the Commission's lockbox
     depository:

          November 26, 1996

                                   SIGNATURES

This  report has been  signed  below by the  following  persons on behalf of the
issuer and in the capacities and on the dates indicated.

By (Signature and Title)*                AMY J. LEE
                          ----------------------------------------
                                   Amy J. Lee, Secretary

Date       November 26, 1996
     -----------------------------

  *Please print the name and title of the signing officer below the signature.

<PAGE>

                     U.S. SECURITIES AND EXCHANGE COMMISSION
                             Washington, D.C. 20549

                                   FORM 24F-2

                        ANNUAL NOTICE OF SECURITIES SOLD
                             PURSUANT TO RULE 24F-2

             READ INSTRUCTIONS AT END OF FORM BEFORE PREPARING FORM.
                              PLEASE PRINT OR TYPE.

 1.  Name and address of issuer:

          Security Equity Fund, 700 Harrison, Topeka, Kansas 66636-0001

 2.  Name of each series or class of funds for which this notice is filed:

          Asset Allocation Series, Class A

 3.  Investment Company Act File Number: 811-1136
     Securities Act File Number:  2-19458

 4.  Last day of fiscal year for which this notice is filed:

          September 30, 1996

 5.  Check box if this  notice is being filed more than 180 days after the close
     of the issuer's fiscal year for purposes of reporting securities sold after
     the close of the fiscal year but before  termination  of the issuer's 24f-2
     declaration:                                                            |_|

 6.  Date of  termination of issuer's  declaration  under rule  24f-2(a)(1),  if
     applicable (see Instruction A.6):

 7.  Number and amount of  securities of the same class or series which had been
     registered  under the  Securities  Act of 1933 other than  pursuant to rule
     24f-2 in a prior fiscal year, but which remained unsold at the beginning of
     the fiscal year:

          None

 8.  Number and amount of  securities  registered  during the fiscal  year other
     than pursuant to rule 24f-2:

          None

 9.  Number and aggregate sale price of securities sold during the fiscal year:

                                    63,688                              $682,087

10.  Number and aggregate  sale price of securities  sold during the fiscal year
     in reliance upon registration pursuant to rule 24f-2:

                                    63,688                              $682,087

11.  Number and aggregate sale price of securities issued during the fiscal year
     in  connection  with  dividend   reinvestment  plans,  if  applicable  (see
     Instruction B.7):

                                     8,801                              $ 89,987

12.  Calculation of registration fee:

     (i)    Aggregate  sale price of  securities  sold during the fiscal year in
            reliance on rule 24f-2 (from Item 10):

                                                                        $682,087

     (ii)   Aggregate  price  of  shares  issued  in  connection  with  dividend
            reinvestment plans (from Item 11, if applicable):

                                                                       +$ 89,987

<PAGE>

                           INVESTMENT COMPANIES-FORMS

12.  Calculation of registration fee (continued):

     (iii)  Aggregate price of shares redeemed or repurchased  during the fiscal
            year (if applicable):

                                                                       -$337,484

     (iv)   Aggregate  price of shares  redeemed or  repurchased  and previously
            applied as a  reduction  to filing  fees  pursuant to rule 24e-2 (if
            applicable):

                                                                       +$      0

     (v)    Net aggregate  price of securities sold and issued during the fiscal
            year in reliance on rule 24f-2 [line (i), plus line (ii),  less line
            (iii), plus line (iv)] (if applicable):

                                                                       -$434,590

     (vi)   Multiplier  prescribed by Section 6(b) of the Securities Act of 1933
            or other applicable law or regulation (see instruction C.6):

                                                                       x  1/3300

     (vii)  Fee due [line (i) or (line (v) multiplied by line (vi)]:

                                                                        $ 131.69

13.  Check box if fees are being remitted to the Commission's lockbox depository
     as described in section 3a of the Commission's  Rules of Informal and Other
     Procedures (17 CFR 202.3a)

                                                                             |X|

     Date of mailing or wire transfer of filing fees to the Commission's lockbox
     depository:

          November 26, 1996

                                   SIGNATURES

This  report has been  signed  below by the  following  persons on behalf of the
issuer and in the capacities and on the dates indicated.

By (Signature and Title)*                AMY J. LEE
                          ----------------------------------------
                                   Amy J. Lee, Secretary

Date       November 26, 1996
     -----------------------------

  *Please print the name and title of the signing officer below the signature.

<PAGE>

                     U.S. SECURITIES AND EXCHANGE COMMISSION
                             Washington, D.C. 20549

                                   FORM 24F-2

                        ANNUAL NOTICE OF SECURITIES SOLD
                             PURSUANT TO RULE 24F-2

             READ INSTRUCTIONS AT END OF FORM BEFORE PREPARING FORM.
                              PLEASE PRINT OR TYPE.

 1.  Name and address of issuer:

          Security Equity Fund, 700 Harrison, Topeka, Kansas 66636-0001

 2.  Name of each series or class of funds for which this notice is filed:

          Asset Allocation Series, Class B.

 3.  Investment Company Act File Number: 811-1136
     Securities Act File Number:  2-19458

 4.  Last day of fiscal year for which this notice is filed:

          September 30, 1996

 5.  Check box if this  notice is being filed more than 180 days after the close
     of the issuer's fiscal year for purposes of reporting securities sold after
     the close of the fiscal year but before  termination  of the issuer's 24f-2
     declaration:                                                            |_|

 6.  Date of  termination of issuer's  declaration  under rule  24f-2(a)(1),  if
     applicable (see Instruction A.6):

 7.  Number and amount of  securities of the same class or series which had been
     registered  under the  Securities  Act of 1933 other than  pursuant to rule
     24f-2 in a prior fiscal year, but which remained unsold at the beginning of
     the fiscal year:

          None

 8.  Number and amount of  securities  registered  during the fiscal  year other
     than pursuant to rule 24f-2:

          None

 9.  Number and aggregate sale price of securities sold during the fiscal year:

                                   104,927                            $1,119,612

10.  Number and aggregate  sale price of securities  sold during the fiscal year
     in reliance upon registration pursuant to rule 24f-2:

                                   104,927                            $1,119,612

11.  Number and aggregate sale price of securities issued during the fiscal year
     in  connection  with  dividend   reinvestment  plans,  if  applicable  (see
     Instruction B.7):

                                     8,014                            $   81,908

12.  Calculation of registration fee:

     (i)    Aggregate  sale price of  securities  sold during the fiscal year in
            reliance on rule 24f-2 (from Item 10):

                                                                      $1,119,612

     (ii)   Aggregate  price  of  shares  issued  in  connection  with  dividend
            reinvestment plans (from Item 11, if applicable):

                                                                     +$   81,908

<PAGE>

                           INVESTMENT COMPANIES-FORMS

12.  Calculation of registration fee (continued):

     (iii)  Aggregate price of shares redeemed or repurchased  during the fiscal
            year (if applicable):

                                                                     -$   55,397

     (iv)   Aggregate  price of shares  redeemed or  repurchased  and previously
            applied as a  reduction  to filing  fees  pursuant to rule 24e-2 (if
            applicable):

                                                                     +$        0

     (v)    Net aggregate  price of securities sold and issued during the fiscal
            year in reliance on rule 24f-2 [line (i), plus line (ii),  less line
            (iii), plus line (iv)] (if applicable):

                                                                      $1,146,123

     (vi)   Multiplier  prescribed by Section 6(b) of the Securities Act of 1933
            or other applicable law or regulation (see instruction C.6):

                                                                     x    1/3300

     (vii)  Fee due [line (i) or (line (v) multiplied by line (vi)]:

                                                                      $   347.31

13.  Check box if fees are being remitted to the Commission's lockbox depository
     as described in section 3a of the Commission's  Rules of Informal and Other
     Procedures (17 CFR 202.3a)

                                                                             |X|

     Date of mailing or wire transfer of filing fees to the Commission's lockbox
     depository:

          November 26, 1996

                                   SIGNATURES

This  report has been  signed  below by the  following  persons on behalf of the
issuer and in the capacities and on the dates indicated.

By (Signature and Title)*                AMY J. LEE
                          ----------------------------------------
                                   Amy J. Lee, Secretary

Date       November 26, 1996
     -----------------------------

  *Please print the name and title of the signing officer below the signature.



<PAGE>

[SBG LOGO]
- --------------------------------------------------------------------------------
Security Benefit Life Insurance Company                700 SW Harrison St.
Security Benefit Group, Inc.                           Topeka, Kansas 66636-0001
Security Distributors, Inc.                            (913) 295-3000
Security Management Company

EXHIBIT 1

November 26, 1996

Security Equity Fund
700 Harrison Street
Topeka, KS 66636-0001

Dear Sir/Madam:

I refer to the Rule 24f-2 Notice for File No. 2-19458 of Security Equity Fund, a
Kansas corporation,  hereinafter  referred to as the "Company," being filed with
the  Securities and Exchange  Commission for the purpose of reporting  under the
Securities  Act of 1933 the  58,276,313  shares of the  $0.25 par value  capital
stock of the Company sold during the fiscal year ended September 30, 1996.

I have  examined  the Articles of  Incorporation  and the bylaws of the Company,
minutes of the applicable meetings of the Board of Directors and stockholders of
the Company,  and other  corporate  records,  applicable  certificates of public
officials, and other documents I have deemed relevant.

Based upon the foregoing, it is my opinion that:

(1)  The Company is duly organized, existing and in good standing under the laws
     of the State of Kansas.

(2)  The Company has authorization to sell 5,000,000,000 shares of capital stock
     of the par value of $0.25 per share pursuant to an indefinite  registration
     of such shares made effective October 25, 1982.

(3)  All  necessary  corporate  actions have been taken to authorize the sale by
     the Company, for the consideration set forth in the registration statement,
     of the 58,276,313  shares (aggregate sale price of $402,814,647) of capital
     stock of the Company,  and,  upon the sale by the Company of those  shares,
     they were duly issued, fully paid and nonassessable.

I hereby  consent to the  inclusion  in said Rule 24f-2  Notice of my  foregoing
opinion filed as Exhibit 1 thereto.

Very truly yours,

AMY J. LEE

Amy J. Lee

Vice President, Associate General Counsel, and Assistant Secretary
Security Benefit Life Insurance Company



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