Exhibit  21




The company's subsidiaries are:

             Name                                      State of Incorporation

  Equitable Life Insurance Company of Iowa                       Iowa
  Equitable Investment Services, Inc.                            Iowa
  Equitable of Iowa Securities Network, Inc.                     Iowa
  Locust Street Securities, Inc.                                 Iowa
  Shiloh Farming Company                                         Louisiana
  Tower Locust, Ltd.                                             Iowa
  Walnut Investments, Ltd.                                       Iowa


All are wholly-owned.

USG Annuity & Life Company, an Oklahoma corporation, and Equitable American
Insurance Company, an Iowa corporation, are wholly-owned subsidiaries of
Equitable Life Insurance Company of Iowa.  In addition, these entities own
other subsidiaries which are not considered in the aggregate to be a
significant subsidiary as defined in Securities and Exchange Commission
rules.

All subsidiaries do business only under their corporate names.