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 June 30, 2000 and 1999, as indicated in our report dated
July 21, 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 June 30, 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
July 21, 2000