EXHIBIT 11

January 27, 2010

SBL Fund
One Security Benefit Place
Topeka, Kansas 66636

Subj:    SBL Fund

Dear Sir or Madam:

As counsel to Security Benefit Corporation, the parent company of Security
Investors, LLC, which serves as investment adviser to SBL Fund (the "Company"),
I am familiar with the business operations, practices and procedures of the
Company. I have reviewed the Company's Registration Statement on Form N-14,
which relates to the Company's authorized shares of common stock, par value of
$1.00 per share (the "Shares"), proposed to be issued in accordance with the
terms of the Plan of Reorganization dated January 21, 2010 (the "Plan"),
including the proposed reorganization of the Company's Series H (Enhanced Index)
into the Company's Series A (Equity).

In connection with rendering the opinions set forth below, I have examined the
Registration Statement, including the Plan, which is being filed as an exhibit
thereto; the Company's Articles of Incorporation and Bylaws; resolutions of the
Board of Directors of the Company relating to the approval of the Plan and the
issuance of the Shares; and such other documents as I deemed relevant. In
conducting my examination, I have assumed the genuineness of all signatures, the
legal capacity of all natural persons, the authenticity, accuracy and
completeness of documents purporting to be originals and the conformity to
originals of any copies of documents. I have not independently established any
facts represented in the documents so relied on.

I am a member of the Bar of the State of Kansas. The opinions expressed in this
letter are based on the facts in existence and the laws in effect on the date
hereof and are limited to the laws (other than the conflict of law rules) of the
State of Kansas applicable to the issuance of shares by registered investment
companies organized as corporations under Kansas law and to the Securities Act
of 1933, as amended, the Investment Company Act of 1940, as amended, and
regulations thereunder. I express no opinion with respect to any other laws.

On the basis of the foregoing, it is my opinion that issuance of the Shares
pursuant to the Plan has been duly authorized by the Company and, when issued
upon the terms provided in the Registration Statement, the Shares 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,

AMY J. LEE

Amy J. Lee
Secretary
Security Investors, LLC