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Security Benefit Life Insurance Company 700 SW Harrison St.
Security Benefit Group, Inc. Topeka, Kansas 66636-0001
Security Distributors, Inc. (785) 431-3000
Security Management Company, LLC
November 17, 2000
Security Growth and Income Fund
700 Harrison Street
Topeka, KS 66636-0001
Dear Sir/Madam:
In connection with the registration under the Securities Act of 1933 of an
indefinite number of shares of common stock of Security Growth and Income Fund
(the "Company"), I have examined such matters as I have deemed necessary to give
this opinion.
On the basis of the foregoing, it is my opinion that the shares have been duly
authorized and, when paid for as contemplated by the Company's Registration
Statement, will be validly issued, fully paid, and non-assessable.
I hereby consent to the filing of this opinion as an exhibit to the Registration
Statement.
Sincerely,
CHRIS SWICKARD
Christopher D. Swickard, Esq.
Assistant Secretary
Security Growth and Income Fund
