Via Facsimile and U.S. Mail
Mail Stop 6010


December 23, 2005


Mr. James W. Noyce
Chief Financial Officer
FBL Financial Group, Inc.
5400 University Ave.
West Des Moines, IA 50266

Re:	FBL Financial Group, Inc.
	Form 10-K for the Fiscal Year Ended December 31, 2004
      Filed March 02, 2005
	File No. 001-11917

Dear Mr. Noyce:

      We have limited our review of your filing to those issues we
have addressed in our comments.  In our comments, we ask you to
provide us with information so we may better understand your
disclosure.  Please be as detailed as necessary in your
explanation.
After reviewing this information, we may raise additional
comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-K for the Fiscal Year Ended December 31, 2004

Management`s Discussion and Analysis of Financial Condition and
Results of Operations for the year ended December 31, 2004





Results of Operations for the Three Years Ended December 31, 2004,
page 25

1. In certain areas of the discussion you make reference to
specific
factors that contributed to the change from period to period.  For
example, please refer to your disclosure on page 26 that discusses
the reasons for increases in premiums and product charges. Where
applicable please provide to us, in disclosure-type format, the
quantification of the individual factors, an analysis explaining
the
relative significance of these items and why the individual
factors
changed.

Contractual Obligations, page 50

2. We note you disclose your insurance liabilities net of expected
reinsurance recoveries.  Amounts in the table should be presented
on
a gross basis consistent with the legal form of the obligation.
Please provide us a table presenting all obligations on a gross
basis.  If you wish to inform investors about recoverables,
disclosure may be presented in a separate table with any necessary
narrative disclosure.

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
letter that keys your response to our comment and provide the
requested information.  Detailed letters greatly facilitate our
review.  Please file your letter on EDGAR under the form type
label
CORRESP.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

	In connection with responding to our comments, please
provide,
in your letter, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Dana Hartz, Staff Accountant, at (202) 551-
3648
or Joseph Roesler, Review Accountant, at (202) 551-3628 if you
have
questions regarding the comments.  In this regard, do not hesitate
to
contact me at (202) 551-3679.


Sincerely,



Jim B. Rosenberg
Senior Assistant Chief
Accountant
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Mr. James W. Noyce
FBL Financial Group, Inc.
December 23, 2005
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