Exhibit 15




StanCorp Financial Group, Inc.
Portland, Oregon


We have made a review, in accordance with standards established by the American
Institute of Certified Public Accountants, of the unaudited interim financial
information of StanCorp Financial Group, Inc. and subsidiaries for the periods
ended March 31, 2000 and 1999, as indicated in our report dated April 24, 2000;
because we did not perform an audit, we expressed no opinion on that
information.

We are aware that our report referred to above, which is included in your
Quarterly Report on Form 10-Q for the quarter ended March 31, 2000, is
incorporated by reference in Registration Statement Nos. 333-78379 and 333-35484
on Form S-8.

We also are aware that the aforementioned report, pursuant to Rule 436(c) under
the Securities Act of 1933, is not considered a part of the Registration
Statement prepared or certified by an accountant or a report prepared or
certified by an accountant within the meaning of Sections 7 and 11 of that Act.




DELOITTE & TOUCHE LLP

Portland, Oregon
April 24, 2000