Exhibit 12

              CONSENT OF INDEPENDENT CERTIFIED PUBLIC ACCOUNTANT




                         Independent Auditors' Consent



The Board of Directors
Paragon Life Insurance Company

We consent to the use of our report included herein on Paragon Life Insurance
Company and to the reference to our firm under the heading "Experts" in the
Registration Statement and Prospectus.


                             /s/ KPMG LLP



St. Louis, Missouri
September 1, 1999