SECURITY EQUITY LIFE INSURANCE CO SEPARATE ACCOUNT 13, 497J, 2000-05-09

SECURITY EQUITY LIFE INSURANCE CO SEPARATE ACCOUNT 13
497J, 2000-05-09

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                             VIA EDGAR
                             ---------

CHRISTOPHER A. MARTIN
Counsel
PHONE:  (314) 444-0499
Fax:    (314) 444-0510

                            May 9, 2000




Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

                  RE:   SECURITY EQUITY LIFE INSURANCE COMPANY
                        SEPARATE ACCOUNT 13
                        FILE NOS. 33-88524 & 811-8938

Ladies and Gentlemen:

Pursuant to Rule 497(j) of the Securities Act of 1933, as amended (the
"Securities Act"), Security Equity Life Insurance Company Separate
Account 13 (the "Registrant") hereby certifies that: (i) the form of
Prospectus that would have been filed under Rule 497(b) of the
Securities Act would not have differed from that contained in Post-
Effective Amendment No. 6 to the Registrant's Registration Statement,
and (ii) the text of Post-Effective Amendment No. 6 was filed
electronically via EDGAR.

If you have any questions regarding this filing, please call me at (314)
444-0499.

                        Sincerely,

                        /s/ Christopher A. Martin

                        Christopher A. Martin