April 17, 2019

Donald J. Seibel
Chief Financial Officer and Treasurer
FBL Financial Group, Inc.
5400 University Avenue
West Des Moines, Iowa 50266-5997

       Re: FBL Financial Group, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2018
           File February 27, 2019
           File No. 001-11917

Dear Mr. Seibel:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment. In our comment, we ask you to
provide us with
information so we may better understand your disclosure.

       Please respond to this comment within 10 business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this comment, we may have additional
comments.

Form 10-K for the Fiscal Year Ended December 31, 2018

Notes to Consolidated Financial Statements
Note 13: Segment Information, page 112

1.    Please represent to us that in future periodic reports on Forms 10-K and
10-Q you will
      remove your discussion and presentation of "non-GAAP operating income"
from your
      financial statement footnote consistent with the requirement in Item
10(e)(1)(ii)(C) of
      Regulation S-K and that you will provide the reconciliation from the
total of your
      segments' profit directly to your pre-tax income as required by ASC
280-10-50-30b.
      Regarding your measures entitled "pre-tax non-GAAP operating income" and
"non-GAAP
      operating revenues," which appear to be your segment profit and segment
revenues
      measures, respectively, under ASC 280-10-50-22, tell us why you label
them as non-
      GAAP.
 Donald J. Seibel
FirstName LastNameDonald J. Seibel
FBL Financial Group, Inc.
Comapany NameFBL Financial Group, Inc.
April 17, 2019
Page 17,
April 2 2019 Page 2
FirstName LastName
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       You may contact Mark Brunhofer at (202) 551-3638 or Jim Rosenberg at
(202) 551-3679
with any questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Healthcare
& Insurance