Exhibit 15



To the Board of Directors of
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, 2001 and 2000, as indicated in our report dated April 20, 2001,
December 6, 2001, as to Note 6 (which includes an explanatory paragraph relating
to the restatement as discussed in Note 6); 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/A for the quarter ended March 31, 2001, 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
December 6, 2001