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Correspondence

 [Letterhead of Gibson, Dunn & Crutcher LLP]

 blane@gibsondunn.com

 August 25, 2005

(202) 887-3646

C 39267-00028

(202) 530-9589

 VIA EDGAR AND OVERNIGHT MAIL

 United States Securities and Exchange Commission

 450 Fifth Street, N.W.

 Mail Stop 6010

 Washington, D.C. 20549

 Attention: Mr. Jim B. Rosenberg, Senior Assistant
Chief Accountant

Re:
Horace Mann Educators Corporation

 Form 10-K for the fiscal year ended December 31, 2004

 Forms 10-Q for quarters ended March 31 and June
30, 2005

 File No. 001-10890

 Dear Mr. Rosenberg:

 On behalf of Horace Mann Educators Corporation (the “Company”), we transmit herein the Company’s responses to the comments in your
August 12, 2005 letter. For ease of reference, the numbered paragraphs below correspond to the numbered comments in your letter, with your comments presented in bold followed by the related response.

 ACCOUNTING COMMENTS

 FORM 10-K FOR THE FISCAL YEAR ENDED DECEMBER 31, 2004

 Item 1 – Business

 Selected Historical Consolidated Financial Data, page 3 and Exhibit 12

1.
Please include the interest paid to policyholders as fixed charges in your calculation of the ratio of earnings to fixed charges and revise your exhibit and disclosures
throughout the filing. Please refer to the Item 503(d) of Regulation S-K.

 United States Securities and Exchange Commission

 August 25, 2005

 Page 2

 Response:

 We note that the language in Item 503(d) of Regulation S-K is unclear as to the requirement of including interest paid to policyholders as fixed charges
in the calculation of the ratio of earnings to fixed charges. However, being made aware of the Staff’s position, in the Company’s next Annual Report on Form 10-K, the Company will revise the exhibit and provide disclosure that includes
interest paid to policyholders as fixed charges in the calculation of the Company’s ratio of earnings to fixed charges.

 Selected Historical Financial Information For Property and Casualty Segment, page 7

2.
We note that you have included “Combined loss and expense ratio before catastrophe loss” in your tabular disclosures herein, and that on page 8 you present claims and
claim expense incurred and payments excluding catastrophes. Similar disclosures are also made in the tables on page F-14 in your MD&A and in the narrative disclosures of your MD&A. Further in the table on page F-19 in your MD&A you
present net income of your Property and Casualty segment before catastrophe costs. We believe that all of these measures are considered non-GAAP measures that must comply with Item 10(e) of Regulation S-K. We note that excluding catastrophes, which
are recurring, to determine these measures has the effect of smoothing earnings. While the acceptability of a non-GAAP financial measure that eliminates recurring items from the most comparable GAAP measure depends on all facts and circumstances, we
do not believe that a non-GAAP measure that has the effect of smoothing earnings is appropriate. In addition, we note that amounts excluded have the following attributes:

•

There is a past pattern of these items occurring in each reporting period;

•

The financial impact of this item will not disappear or become immaterial in the future; and

•

There is no unusual reason that the company can substantiate to identify the special nature of this item especially in view of the nature of the company’s business.

 These attributes raise significant questions
about management’s assertions as to the usefulness of these measures for investors and the appropriateness of their presentation in accordance with Item 10(e) of Regulation S-K. Please refer to “Frequently Asked Questions Regarding the Use
of Non-GAAP Financial Measures” on our website at www.sec.gov/divisions/corpfin/faqs/nongaapfaq.htm that we issued on June 13, 2003, specifically questions 8 and 20. As it appears that you have not

 United States Securities and Exchange Commission

 August 25, 2005

 Page 3

 adequately disclosed the usefulness or the appropriateness of these measures as required by Item 10 of Regulation S-K, please remove all references to
them in your filing. Although we object under your current disclosure of presenting measures that exclude catastrophe loss, we encourage you to disclose the amount of catastrophe losses and provide narrative disclosure about catastrophe losses in a
context that improves the transparency of your disclosure to explain the reasons for fluctuations of line items from period to period.

 Response:

 We are aware of the Staff’s close scrutiny of non-GAAP measures, especially those that omit recurring items. We respectfully submit that the impact
of catastrophes is something of special interest to shareholders of a property & casualty insurance company. It is a topic that is often raised by the investment community after any catastrophe. This was especially true in 2004 when the losses
resulting from four hurricanes in Florida were very severe and occurred within a six-week period. In light of the recurring but unpredictable volatility of catastrophe losses, the Company has supplementally included these non-GAAP measures to
provide the investment community with meaningful additional disclosure to understand the underlying operating results. The Company’s management believes that the presentation of GAAP results in conjunction with total losses, catastrophes and
amounts without catastrophes was a balanced presentation giving appropriate consideration to total losses and only using the later with and without catastrophe amounts to highlight one of the most significant contributors to volatility.

 Nevertheless, the Company is prepared to exclude such supplemental
disclosure in its future periodic reports, opting instead to disclose the amount of catastrophe losses and provide narrative disclosure about catastrophe losses as appropriate given their impact on the Company’s operations and financial
statements as suggested by the Staff without creating a non-GAAP measure. The Company may continue to use these supplemental measures in future earnings releases and will undertake to be mindful of the guidance in FAQ #8 for additional disclosure in
such circumstances.

 Management’s discussion and analysis of
financial condition and results of operations, page F-2

 Critical Accounting Policies – Liabilities for Property and Casualty Claims and Claim Settlement Expenses, page F-4

3.
We believe your disclosure in Management’s Discussion and Analysis regarding the reserve for loss and loss adjustment expenses could be improved to better explain the
judgments and uncertainties surrounding this estimate and the potential impact on your financial statements. We believe that disclosures explaining the likelihood

 United States Securities and Exchange Commission

 August 25, 2005

 Page 4

 that materially different amounts would be reported under different conditions or using different assumptions is consistent with the objective of
Management’s Disclosure and Analysis. Accordingly, please revise MD&A to include the following information for each of your lines of business (private passenger automobile and homeowners).

•

Please disclose the reserves accrued as of the latest balance sheet date presented. The total of these amounts should agree to the amount presented on the balance sheet.

•

Please disclose the range of loss reserve estimates as determined by your actuaries. Discuss the key assumptions used to arrive at management’s best estimate of loss
reserves within that range and what specific factors led management to believe this amount rather than any other amount within the range represented the best estimate of incurred losses.

•

If you do not calculate a range around your loss reserve, but instead use point estimates please include the following disclosures:

•

Disclose the various methods considered and the method that was selected to calculate the reserves. If multiple point estimates are generated, include the range of these point
estimates. Include a discussion of why the method selected was more appropriate over the other methods.

•

Discuss how management determined the most appropriate point estimate and why the other point estimates were not chosen. Also clarify whether the company actually records to the
point estimate or if not, how that estimate is used.

•

Include quantified and narrative disclosure of the impact that reasonably likely changes in one or more of the variables (i.e. actuarially method and/or assumptions used) would
have on reported results, financial position and liquidity.

•

Because IBNR reserve estimates are more imprecise, please disclose the amount of IBNR separately from case reserves for all lines of business.

 Response:

 In future filings, the Company will disclose the reserves accrued as of the latest balance sheet date presented. The Company
does not estimate a range around its loss reserves, but does consider point estimates derived by using multiple methodologies. In future filings, the

 United States Securities and Exchange Commission

 August 25, 2005

 Page 5

 Company will disclose in narrative and/or tabular form, as appropriate, the following information:

•

The various methodologies considered and the methodology or methodologies selected or given prominent consideration to estimate the reserves. When multiple estimates are generated,
information concerning such estimates and a discussion of the rationale for the point estimate selected.

•

How management determined the most appropriate point estimate and why the other estimates were not chosen. Whether the Company actually records to the point estimate or if not, how
that estimate is used.

•

Narrative disclosure of the impact that reasonably likely changes in one or more of the variables (i.e. actuarial method and/or assumptions used) would have on reported results,
financial position and liquidity.

 In addition,
in future filings, the Company will disclose in tabular form the amount of IBNR reserves separately from case reserves for the Company’s primary lines of business.

 Contractual Obligations, page F-23

4.
We note that the Company did not include “policy liabilities” and “variable annuity liabilities” shown on the balance sheet and lease obligations to be paid
in the contractual obligation table. It would appear that these liabilities/obligations, with the exception of unearned premiums, represent future legal obligations of the Company. Due to their significant nature to your business, we believe that
their inclusion in the contractual obligation table will provide investors increased disclosure of your liquidity. The purpose of Financial Reporting Release 67 is to obtain enhanced disclosure concerning a registrant’s contractual payment
obligations and the exclusion of ordinary course items would be inconsistent with the objective of the Item 303(a)(5) of Regulation S-K. Based on the above factors, please revise your contractual obligation table to include the expected settlement
of your policy and annuity liabilities and the expected payments on operating leases.

 Response:

 In the Company’s next Annual Report on Form 10-K, the Company will revise the contractual obligation table to include the expected settlement of
policy liabilities that are obligations of its general accounts as well as the expected payments on operating leases. As set forth in the response to comment #5 below, the Company’s variable annuity liabilities are separate account liabilities.
Separate account payments would not be reflected due to the matched nature of these obligations and the fact that the contract owners maintain the investment risk of such deposits. In the Company’s next Annual Report on Form 10-K, the Company
will revise the contractual obligation table to include disclosure to clarify this point.

 United States Securities and Exchange Commission

 August 25, 2005

 Page 6

 Consolidated Financial Statements

 Consolidated Balance Sheets, page F-32

5.
Please tell us why you have separately classified “Variable Annuity Assets” outside of “investments” and why you do not identify the nature of the investments
on the face of the balance sheet in one of the categories listed in Rule 7-03(a)1 of Regulation S-X consistent with your other investments. Also tell us why you don’t classify your “Variable Annuity Liabilities” under “policy
liabilities” on the face of the balance sheet. Further, with respect to your disclosure in Note 1 — Variable Annuity Assets and Liabilities, please tell us what the various “Horace Mann” funds represent in 2003.

 Response:

 The Company’s financial statement line item entitled “Variable
Annuity Assets” consists of assets held in separate accounts relating to variable annuity (or separate account) liabilities. Accordingly, in accordance with Rule 7-03(a)11 of Regulation S-X, the Company has presented these assets
separately from investments. In future filings, the Company will clarify this in the financial statement line caption.

 Similarly, the Company’s financial statement line item entitled “Variable Annuity Liabilities” consists of separate account obligations. As
a result, in accordance with Rule 7-03(a)18 of Regulation S-X, the Company has presented these obligations separately from its policy liabilities. In future filings, the Company will clarify this in the financial statement line caption.

 Prior to 2004, the “Horace Mann” funds represented
variable annuity funds within the separate account invested in proprietary mutual funds, which were sponsored by the Company. This disclosure in Note 1 — Variable Annuity Assets and Liabilities was historically provided because the Horace Mann
mutual funds had related party characteristics. In 2004, the Company ceased sponsorship of these mutual funds and therefore they were no longer affiliated with the Company.

 Note 1 Deferred Policy Acquisition Cost, page F-38

6.
Please tell us how your use of “gross margin” for interest sensitive life contracts and investment contracts complies with “gross profit” as used in paragraph
23 of FAS 97. Further, tell us whether you base your amortization on the “present value” of gross profit as required by paragraph 22. Clarify your disclosure, as appropriate.

 United States Securities and Exchange Commission

 August 25, 2005

 Page 7

 Response:

 The use of “gross margin” for interest sensitive life contracts and investment contracts is used synonymously with “gross profit” as
contained in paragraph 23 of FAS 97. The Company will use the term “gross profit” in future filings. The Company does base its amortization on the present value of estimated gross profits as required by paragraph 22 of FAS 97 and will add
this clarification in future filings.

7.
Please tell us how your method of amortizing deferred acquisition costs for investment contracts complies with paragraph 10.33 of AICPA Audit and Accounting Guide for Life and
Health Insurance Entities.

 Response:

 Paragraph 10.33 of AICPA Audit and Accounting Guide for Life
and Health Insurance Entities (the “Life and Health Audit Guide”) relates to alternative bases for DAC amortization if significant negative gross profits are expected in any period. Due to the fact that negative gross profits are
not expected in any period, the Company does not utilize alternative DAC amortization bases and the guidance in paragraph 10.33 of the Life and Health Audit Guide is not applicable.

8.
Please tell us whether or not the “valuation of annuity and life deferred acquisition costs” discussed on F-18 under “Amortization of Policy Acquisition Expenses
and Intangible Assets” represent the “adjustments” you describe in the last sentence of the first paragraph herein.

 Response:

 The Company confirms that the “valuation of annuity and life deferred acquisition costs” discussed on F-18 under “Amortization of Policy
Acquisition Expenses and Intangible Assets”