May 13, 1999


RE: PRINCIPAL LIFE'S SURVIVORSHIP FLEXIBLE PREMIUM VARIABLE UNIVERSAL 
    LIFE INSURANCE POLICY

Dear Sir or Madam:

In my capacity as Senior Actuarial Associate of Principal Life Insurance Company
("Principal   Life"),  I  have  provided   actuarial  advice   concerning,   and
participated in the design of Principal  Life's  Survivorship  Flexible  Premium
Variable  Universal  Life  Insurance  Policy  (the  "Policy").  I also  provided
actuarial advice concerning the preparation of a registration  statement on form
S-6 for filing with the Securities and Exchange  Commission under the Securities
Act of 1933 in connection with the Policy. In my opinion:

         a)   the  federal   tax  charge  of  1.25%  of  premium  for   deferred
              acquisition  costs is reasonable  in relation to Principal  Life's
              increased  tax burden under  Section 848 of the  Internal  Revenue
              Code  of 1986  as  amended.  In  addition,  it is my  professional
              opinion that the 15% rate of return,  and the assumptions on which
              that rate is based,  are reasonable  for use in  calculating  such
              charges.

         b)   the  illustrations  of death benefits,  account values,  surrender
              values and accumulated premiums in the prospectus are based on the
              assumptions  stated  in the  illustrations,  consistent  with  the
              provisions on the Policy. Such assumptions,  including the assumed
              current  charge  levels  are  reasonable.  The Policy has not been
              designed  so as to  make  the  relationship  between  premium  and
              benefits,   as  shown   in  the   illustrations,   appear   to  be
              correspondingly  more favorable to a prospective  purchaser of the
              Policy at the ages,  genders and underwriting  classes shown, than
              to prospective  purchasers at other ages, genders and underwriting
              classes.  Nor were the particular  illustrations  selected for the
              purpose of making this relationship appear more favorable.

I hereby  consent to the use of this  opinion as an exhibit to the  registration
statement  and to the  reference  to my name under the heading  "Experts" in the
prospectus.

Very truly yours,


/s/ Jeff Fitch


Jeff Fitch, FSA, MAAA
Senior Actuarial Associate
Phone:  515-235-5898
Fax:  515-362-0056