SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Via Facsimile and U.S. Mail
Mail Stop 6010

									December 23, 2005

Melinda S. Urion
Executive Vice President,
Chief Financial Officer and Treasurer
AmerUs Group Co.
699 Walnut Street
Des Moines, Iowa 50309

Re:  	AmerUs Group Co.
      Form 10-K for the Fiscal Year Ended December 31, 2004
      Filed March 7, 2005
      File Number:  001-15166

Dear Ms. Urion:

      We have limited our review of your filing to the issues we
have
addressed in our comments.  In our comments, we ask you to provide
us
with additional information so we may better understand your
disclosures.  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 on 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 year ended December 31, 2004

Management`s Discussion and Analysis of Financial Condition and
Results of Operations, page 23
Off-Balance Sheet Arrangements, page 36
Summary of Contractual Obligations and Commitments, page 36

1. We note that the amount presented for annuity and other non-
life
insurance payments does not agree to the balance sheet.  Please
provide to us a reconciliation and discussion that explains how
this
number relates to the amounts presented in your balance sheet.

Critical Accounting Policies, page 36
Amortization of DAC and VOBA, page 38

2. Please provide to us in disclosure type format the impacts that
changes in these estimates have had in the period presented.
Include
a discussion of the sensitivity of these estimates to reasonably
possible changes in these assumptions.

Item 7A.  Quantitative and Qualitative Disclosures About Market
Risk,
page 55

3. We note that you reference your discussion in note 4 related to
the derivative instruments in this discussion.  It does not seem
that
the discussion included in that note provides sufficient
information,
such as the fair value of the options that come due in each of the
next five years, to understand the quantified impact that these
derivatives will have on your financial information.  Please
provide
to us in disclosure type format the information that details the
impact and sensitivity that these financial instruments will have
on
your financial statements.

Consolidated Financial Statements, page F-1

(9)  Income Taxes, page F-37

4. Please explain to us in greater detail what resulted in the
release of certain tax accrual reserves.  Include specifically the
information available that resulted in the original recording of
the
provisions and what changed to result in the release of these
accruals in the current year.

(12)  Commitments and Contingencies, page F-45

5. We note your discussion on page F-46 of a class action lawsuit
in
the State of California and that the plaintiffs are seeking a
variety
of damages.  Please provide to us in disclosure type format a
discussion of the actual stated dollar amounts that are being
sought
for with these damages as we feel that this represents the upper
end
of the range of potential outcomes related to this lawsuit.  If no
actual amounts are disclosed, then make it clear that there is not
an
expressed amount in the lawsuit and why you are unable to include
such amounts or at least a discussion of these amounts given that
you
should be able to determine at a minimum the surrender charges
subject to restitution.

* * * *

	Please provide us the additional information requested within
10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your response that keys your
response to our comments  Detailed cover 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 Vanessa Robertson, Staff Accountant, at (202) 551-
3649 or Jim Atkinson, Accounting Branch Chief, at (202) 551-3674
if
you have any 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
??

??

??

??

Melinda S. Urion
AmerUs Group Co.
December 23, 2005
Page 1

</TEXT>
</DOCUMENT>