November 9, 2000


IDS Life Insurance Company of New York
20 Madison Avenue Extension
Albany, NY 12203

Gentlemen:

This opinion is furnished in connection with the  Pre-Effective  Amendment No. 1
(Amendment)  by IDS Life  Insurance  Company  of New York for the  filing of the
Flexible Premium Variable Life Insurance Policy ("the VUL-3NY Policy"), File No.
333-44644, under the Securities Act of 1933. The prospectus included on Form S-6
in the Amendment  describes the VUL-3NY  Policy.  I am familiar with the VUL-3NY
Policy, the Amendment and the exhibits thereto. In my opinion, the illustrations
of Death Benefits,  Policy Values,  and Surrender Values included in the section
of the prospectus entitled "Illustrations", under the assumptions stated in that
section, are consistent with the provisions of the VUL-3NY Policy.

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 this
prospectus.

Very Truly Yours,


/s/ Mark Gorham
    Mark Gorham, F.S.A., M.A.A.A.
    Actuarial Director - Insurance Product Development