Exhibit 99
                          RISK MANAGEMENT


Disclosure - General Comment
----------------------------

     When used or incorporated by reference in disclosure documents, the words
"anticipate", "estimate", "expect", "project", "target", "goal" and similar
expressions are intended to identify forward-looking statements within the
meaning of Section 27A of the Securities Act of 1933.  These forward-looking
statements are subject to certain uncertainties, risks and assumptions.
Should one or more of these risks or uncertainties materialize, or should
underlying assumptions prove to be inaccurate, the actual results may vary
materially from those anticipated, estimated, expected or projected.
Additionally, these forward-looking statements are relevant only as of the
date of the document.  The Company's management expressly disclaims any
obligation to publicly release updates or revisions to any forward-looking
statement contained herein to reflect changes in the Company's expectations
with regard to any change in events, conditions or circumstances on which any
such statement is based.

Market Risk
-----------

     Generally, market risk represents the risk of loss that may occur due to
potential changes in a financial instrument's valuation or cash flow due to
changes in interest rates, currency exchange rates, and in equity and
commodity prices.  Market risk is inherent to both derivative and
non-derivative financial instruments.

General Risk Management Procedures
----------------------------------

     The Company's Investment Committee has oversight responsibilities for all
operational and other matters that affect the Company's day-to-day investment
activities.  The Investment Committee monitors the market risk faced by the
Company's various entities and portfolios.  The asset and liability management
strategy are formulated and monitored by the Investment Committee.  The
Committee meets monthly to review, among other things, statements detailing
the Company's market risks and trends, portfolio holdings at book and market
value, equity exposure and surplus positions, and interest rate scenario
stress tests.  The stress testing provides insights into the sensitivity of
the assets to interest rate changes.  The committee is comprised of the Chief
Executive Officer, Chief Investment Officer, Chief Financial Officer and other
senior executives.  The Company also conducts extensive cash flow testing on
an annual basis for the Farmers Life book of business.  This review examines
the adequacy of reserves under various interest rate environments.  The
Company examines the asset and liability matching throughout the year using
quarterly scenario tests and monthly asset duration reports.  This Committee
also reviews investment policies and procedures and makes recommendations to
the Board of Directors of the Company based upon the results of their review.

     In addition, Farmers Life's Interest Committee has responsibility for
managing spreads between rates credited on interest-sensitive products and
portfolio earnings rates.  The Interest Committee is comprised of the
following Farmers Life personnel:  President, Actuary, Treasurer, VP-Insurance
Operations, VP-Staff Operations, AVP-Information Systems, AVP-Annuities and
Life Marketing Director.

     The Company has contracted with Scudder Kemper Investments, Inc. ("SKI")
for the purpose of providing investment advice, trade execution and other
investment related services.

     SKI utilizes a number of market risk management tools including, but not
limited to, fixed income securities interest rate sensitivity analysis,
following established limits on trading activity and asset allocation, marking
all equity positions to market on a daily basis, marking all fixed income
positions to market at least monthly and analyzing investment profit and loss
statements and investment holding asset class mix reports.  Additionally, SKI
reports positions, profits and losses, credit quality evaluation results and
trading strategies, including the period's acquisitions and dispositions to
the Investment Committee on a monthly basis.  The Company believes that these
procedures, which focus on meaningful communication between SKI and the
Company's senior management, are one of the most important elements of the
risk management process.

<PAGE>   2

     Although the Company has a number of procedures to reduce the level of
exposure to interest rate risk and equity price risk, the Company continues
to remain vulnerable to both of these market risks.  There can be no assurance
that the Company will not experience changes in stockholders' equity, net
income and net interest income during periods of increasing or decreasing
interest rates and/or equity prices.

     The Company's management does not anticipate any significant changes in
the way it currently manages market risks.

Primary Market Risk Exposures
-----------------------------

     The Company's exposure to market risk is primarily attributable to the
interest rate risk and equity price risk inherent in the Company's investment
related activities and in the Company's annuity product underwriting
activities.  To a lesser extent, the Company has exposure to interest rate risk
as a result of its issuance of Cumulative Quarterly Income Preferred
Securities ("QUIPS").

     A description of the Company's primary market risk exposures as of
December 31, 1999 and a brief narrative explaining how each exposure is
currently being managed follows:

Interest Rate Risk
------------------

     The Company has significant exposure to interest rate risk primarily as
a result of maintaining an investment portfolio which includes interest rate
sensitive financial instruments and as a consequence of underwriting interest
rate sensitive annuity products.  Therefore, the Company exposes itself to
interest rate risk, arising from changes in the level or volatility of
interest rates, mortgage prepayment speeds or the shape and slope of the yield
curve.  Additionally, the fair value of the Company's QUIPS has exposure to
interest rate risk.

     In general, the fair values of fixed-rate financial instruments have an
inverse correlation to changes in interest rates.  Therefore, an increase in
interest rates could result in an unfavorable or untimely decrease in the
market value of the Company's fixed income investments.  Furthermore, the
Company has classified all of its marketable fixed income investments as
available-for-sale as defined by SFAS No. 115, with the exception of $59.7
million in 1999 which relate to a grantor trust and are classified as trading
securities as defined by SFAS No. 115.  The available-for-sale fixed income
investments are reported on the consolidated balance sheet at market value,
with unrealized gains and losses, net of tax, excluded from earnings and
reported as a component of stockholders' equity.  The trading investments are
reported on the "Other assets" line of the consolidated balance sheet at market
value with both realized and unrealized gains and losses included in earnings,
net of tax, in the year in which they occur.  As such, an increase in interest
rates could adversely affect the Company's stockholders' equity.

     Generally, the change in fair value of the Company's QUIPS (see Note G),
BAFS notes receivable and OSDH note receivable (see Note S), investments in
certificates of contribution and the surplus note of the P&C Group (see Note F)
that may arise due to changes in interest rates would not be reflected in the
Company's consolidated financial statements, since these financial instruments
are not classified as marketable securities pursuant to SFAS No. 115.

Exposure Management
-------------------

     The principal objective of the Company's interest rate risk management
activities are to evaluate the interest rate risk included in certain balance
sheet accounts, determine the level of risk appropriate given the Company's
business objectives, operating environment, capital and liquidity requirements
and performance objectives and to manage this risk consistent with approved
guidelines.

     Farmers Life employs various methodologies to manage its exposure to
interest rate risks.  Its asset/liability matching process focuses primarily
on the management of interest rate risk.  The duration of insurance liabilities
is compared to the duration of assets backing the insurance product lines,
measured in terms of cash flows.  The goal is to prudently balance
profitability and risk for each insurance product class and for Farmers Life
as a whole.

<PAGE>   3

     Farmers Life also considers the timing of cash flows arising from market
risk sensitive instruments and insurance portfolios under varying interest
rate scenarios (cash flow testing) to verify its ability to meet future
obligations.  Although these activities seek to reduce interest rate
exposures, a change in levels of interest rates remains an uncertainty that
could have an impact on the fair values or earnings of the Company.

Quantitative Disclosure of Interest Rate Risk
---------------------------------------------

     The table below represents a summary of the par values of the Company's
financial instruments at their expected maturity dates, the weighted average
coupons by those maturity dates and the estimated fair value of those
instruments for the period ended December 31, 1999.  The expected maturity
categories take into consideration par amortization (for mortgage backed
securities), call features and sinking fund features.

     The estimated market value of available-for-sale securities is based on
bid quotations from security dealers or on bid prices published in news quote
services.  The fair value of BAFS notes receivable, OSDH note receivable,
QUIPS, certificates of contribution of the P&C Group, the surplus note of the
P&C Group, mortgage loans, policy loans and future policy benefits, were
analytically determined utilizing discounted cash analysis.  December 31, 1999
market interest rates were used as discounting rates in the estimation of fair
value.

     Generally, the assets included in the table below have fixed stated
interest rates.  The QUIPS also have fixed stated rates; whereas, the future
policy benefits-deferred annuities generally include variable rate contract
terms.

<PAGE>   4

                               Financial Instruments - With Interest Rate Risk
                                         As of December 31, 1999
                                          (Amounts in thousands)

<TABLE>
<CAPTION>
                                                     Expected Maturity Date
                                                                                     There      Total
                                12/31/00  12/31/01  12/31/02  12/31/03  12/31/04     After    Par Value   Fair Value
                                --------  --------  --------  --------  --------  ----------  ----------  ----------
<S>                             <C>       <C>       <C>       <C>       <C>       <C>         <C>         <C>
Noninsurance
----------------
Assets -
 Debt Securities Available-
  For-Sale:
   U.S. Treasury Securities &
    Other Obligations of U.S.
    Government                  $      -  $    235  $      -  $      -  $      -  $        -  $      235  $      240
     Weighted Avg Coupon           7.88%     7.88%      0.00%     0.00%     0.00%       0.00%
   Obligations of States &
    Political Subs              $ 39,415  $139,140  $130,465  $ 95,180  $ 50,385  $    6,210  $  460,795  $  473,097
     Weighted Avg Coupon           5.83%     5.90%     5.71%     5.25%     4.69%       4.69%
   Corporate Securities         $ 15,000  $ 20,535  $      -  $      -  $ 10,000  $       20  $   45,555  $   44,952
     Weighted Avg Interest Rate    6.70%     6.50%     6.35%     6.35%     6.35%       6.35%
   Mortgaged-Backed Securities  $ 13,996  $  1,880  $ 11,653  $  2,003  $  2,782  $   10,121  $   42,435  $   41,364
     Weighted Avg Coupon           3.05%     6.20%     6.55%     6.53%     6.51%       6.51%
   Other Debt Securities        $  2,500  $      -  $ 13,728  $  2,250  $      -  $        -  $   18,478  $   18,613
     Weighted Avg Coupon           6.70%     6.70%     4.30%     2.00%     2.00%       2.00%

   Mortgage Loans               $     54  $     59  $     33  $      -  $      -  $        -  $      146  $      152
     Weighted Avg Interest Rate     9.5%      9.5%      9.5%      0.0%      0.0%        0.0%

   Notes Receivable-Affiliates  $200,000  $207,000  $200,000  $200,000  $500,000  $        -  $1,307,000  $1,280,685
     Weighted Avg Interest Rate    6.00%     6.11%     6.25%     6.43%     6.76%

   Certificates of Contribution
    of the P&C Group            $      -  $      -  $      -  $      -  $      -  $   23,330  $   23,330  $   23,330
     Weighted Avg Interest Rate    8.48%     8.48%     8.48%     8.48%     8.48%       8.48%

Liabilities -
   QUIPS                        $      -  $      -  $      -  $      -  $      -  $  500,000  $  500,000  $  448,668
     Weighted Avg Interest Rate    8.41%     8.41%     8.41%     8.41%     8.41%       8.41%


Insurance Subsidiaries
----------------------
Assets -
 Debt Securities Available-
  For-Sale:
   U.S. Treasury Securities &
    Other Obligations of U.S.
    Government                  $      -  $      -  $  1,500  $ 10,025  $ 42,000  $  318,815  $  372,340  $  397,859
     Weighted Avg Interest Rate    7.29%     7.29%     7.22%     7.29%     6.48%       6.63%
   Obligations of States &
    Political Subs              $ 27,170  $ 11,071  $ 27,976  $ 35,255  $ 58,670  $  321,060  $  481,202  $  485,340
     Weighted Avg Interest Rate    6.46%     6.32%     6.45%     6.48%     6.80%       6.74%
   Debt Securities Issued By
    Foreign Governments         $      -  $  9,786  $  2,784  $  2,018  $  3,846  $   78,505  $   96,939  $   76,699
     Weighted Avg Interest Rate    8.56%     8.14%     8.56%     7.99%     8.25%       9.08%
   Corporate Securities         $ 41,233  $136,374  $ 95,187  $205,323  $164,961  $  723,805  $1,366,883  $1,327,284
     Weighted Avg Interest Rate    7.43%     7.59%     7.39%     7.44%     7.53%       7.46%
   Mortgage-Backed Securities   $ 90,044  $ 91,103  $186,415  $218,753  $232,004  $1,664,518  $2,482,837  $2,024,284
     Weighted Avg Interest Rate    5.55%     5.50%     5.39%     5.21%     4.94%       4.83%
   Other Debt Securities        $    114  $     39  $     75  $    137  $     17  $      818  $    1,200  $   64,854
     Weighted Avg Interest Rate    3.59%     3.33%     3.19%     3.17%     2.57%       2.47%

   Surplus Note of the P&C
    Group                       $      -  $119,000  $      -  $      -  $      -  $        -  $  119,000  $  119,000
     Weighted Avg Interest Rate    6.10%     6.10%     0.00%     0.00%     0.00%       0.00%
   Mortgage Loans               $  4,068  $  6,505  $ 15,872  $  4,566  $  2,895  $    7,878  $   41,784  $   43,818
     Weighted Avg Interest Rate    9.91%     9.88%     9.84%     9.88%     9.95%       9.88%
   Policy Loans                 $ 11,047  $ 10,135  $  9,031  $  8,448  $  8,165  $  154,861  $  201,687  $  199,166
     Weighted Avg Interest Rate    7.60%     7.60%     7.60%     7.60%     7.60%       7.60%

Liabilities -
   Future Policy Benefits -
    Deferred Annuities          $119,465  $114,867  $108,280  $100,779  $ 92,447  $  906,977  $1,442,815  $1,392,500
     Weighted Avg Interest Rate    5.54%     5.54%     5.54%     5.54%     5.54%       5.54%

</TABLE>

<PAGE>   5

Equity Price Risk
-----------------

     As a consequence of maintaining an investment portfolio composed of
equity securities and maintaining purchased S&P 500 call options that hedge
certain liabilities created as a result of underwriting equity-linked annuity
products, the Company is exposed to equity price risk.  Equity price risk
arises as a result of changes in the level and volatility of equity prices
which in turn affect the value of equity securities and/or instruments that
derive their value from a particular equity security, basket of equity
securities or an equity securities index.

     The Company has classified all of its marketable equity investments as
available-for-sale as defined by SFAS No. 115, with the exception of $59.7
million in 1999 which relate to a grantor trust and are classified as trading
securities as defined by SFAS No. 115.  The available-for-sale equity
investments are reported on the consolidated balance sheet at market value,
with unrealized gains and losses, net of tax, excluded from earnings and
reported as a component of stockholders' equity.  The trading investments are
reported on the "Other assets" line of the consolidated balance sheet at market
value with both realized and unrealized gains and losses included in earnings,
net of tax, in the year in which they occur.  As such, an increase in interest
rates could adversely affect the Company's stockholders' equity.

     The Company's equity price risk relative to its underwriting of equity-
linked annuity products exists as a result of the potential liability that may
exist at the end of these product's contract terms.  At the end of a seven
year term, these annuity products credit interest to the annuity participant
at a rate based on a specified portion of the change in the value of the
S&P 500, subject to a guaranteed annual minimum return.  As such, an increase
in the S&P 500 could increase the liability due at the maturity of these
annuity products and adversely affect the Company's stockholders' equity.

Exposure Management
-------------------

     On a monthly basis, the Investment Committee evaluates the level of
equity price risk that it believes the Company should carry giving
consideration to, among other things, the ratio of investments in equity
securities as a percentage of stockholders' equity.   Management utilizes a
number of equity price risk management tools including, but not limited to,
reviewing equity investment trading activity, marking all equity positions to
market daily, analyzing investment profit and loss statements and reviewing
the industry sector allocation and capitalization mix of the Company's
investments in marketable equity securities.

     As indicated above, the Company is exposed to equity price risk
(primarily the S&P 500) as a consequence of underwriting equity-linked annuity
products through Farmers Life.  However, the Company addresses this risk
through a controlled program of risk management that includes the use of
derivative financial instruments.  The Company purchases S&P 500 call options
to reduce the exposure to rising equity prices that results from underwriting
the equity linked annuity product.  Call options are contracts that grant the
purchaser the right to buy the underlying index on a certain date for a
specified price.  The Interest Committee of Farmers Life monitors option
market pricing and manages the participation rate on the equity-linked annuity
products to minimize the associated equity price risk.  See Note K of the
Company's consolidated financial statements.

Quantitative Disclosure of Equity Price Risk
--------------------------------------------

     The table below represents a sensitivity analysis of the equity price
risk that exists within the Company's investment in equity financial
instruments.  The equity market risk associated with the equity-linked annuity
products is substantially offset by the related option contracts, therefore,
these instruments taken as a whole, do not materially impact the Company's
market risk position.  As such, the table below focuses on the equity
instrument securities. The Noninsurance and the Insurance Subsidiaries
equity investment portfolios have weighted average betas of .98 and .97,
respectively.  The weighted average beta is calculated as the portfolio
weighted average of the individual asset betas.  The individual asset betas
are calculated using sixty months of historical data.  The individual asset
betas are calculated relative to a broadly defined universe of approximately
8,000 assets.  Then a portfolio beta is calculated for both the Company's
portfolio and the benchmark Russell 3000 index.  The weighted average beta is
equal to the ratio of the portfolio beta to the Russell 3000 beta.


<PAGE>  6

     In light of the Company's weighted average beta, the Company expects the
market value of its equity investment portfolio to have a strong correlation
to movements in the Russell 3000 index.  As indicated in the table below, if
the Russell 3000 index were to move by a positive or negative 10%, the Company
estimates that there would be a corresponding 9.8% change in the market value
of Noninsurance's investment in equity securities and a 9.7% change in the
market value of the Insurance Subsidiaries' investment in equity securities.
The change in the market value of the Company's investments in equity
securities would be in the same direction as the change in the Russell 3000
index.

                        Trading Financial Instruments - With Equity Price Risk
                                     As of December 31, 1999
                                      (Amounts in thousands)
<TABLE>
<CAPTION>
                                                                         Estimated          Estimated
                                                                          Value If           Value If
                                                                        Russell 3000       Russell 3000
                                    Historical        Market Value    Index Increased    Index Decreased
                                    Cost Basis         12/31/1999          By 10%             By 10%
                                  ---------------   ---------------   ---------------   ---------------
<S>                               <C>               <C>               <C>               <C>
Noninsurance
------------
       Equity Investments         $       299,251   $       334,212   $       366,965   $       301,459

Insurance Subsidiaries
----------------------
       Equity Investments         $       190,004   $       213,432   $       234,135   $       192,729

</TABLE>

Foreign Exchange Rate Risk
--------------------------

     Foreign exchange rate risk arises from the possibility that changes in
foreign exchange rates will impact the value or cash flows of financial
instruments.  When a company buys or sells a financial instrument denominated
in a currency other than US dollars, exposure exists from the net open
currency position.  Until the position is covered by the selling or buying of
an equivalent amount of the same currency or by entering into a financing
arrangement denominated in the same currency, a company is exposed to a risk
that the exchange rate may move in an unfavorable direction against the US
dollar.

     The Company does not have any material holdings of financial instruments
denominated in a currency other than U.S. dollars as of December 31, 1999.


Credit Risk
-----------

     Credit risk arises from the potential inability of a counterparty to
perform on an obligation in accordance with the terms of the contract.  The
Company's primary credit risk exposure exists as a result of maintaining both
a fixed income investment portfolio and a mortgage loan portfolio.  As a
holder of these financial instruments, the Company is exposed to default by
the issuer or to the possibility of market price deterioration as a
counterparty may experience deterioration in its credit quality.  The Company
has established policies and procedures to manage this credit risk. For
example, the Investment Committee is responsible for monitoring the credit
quality of securities positions held in the Company's fixed income investment
portfolios in order to quantify and limit the risk to the Company of issuer
default or changes in credit spreads.  The Company's management does not
believe that there are any concentrations of credit risk to unaffiliated
parties as of the year ended December 31, 1999.  The Company does not
currently use derivative products to manage credit risk.