April 26, 2002


American Enterprise Life Insurance Company
829 AXP Financial Center
Minneapolis, MN 55474


RE:      American Enterprise MVA Account
         American Express FlexChoice Variable Annuity
         American Express Galaxy Premier Variable Annuity
         American Express Innovations Variable Annuity
         American Express New Solutions Variable Annuity
         American Express Pinnacle Variable Annuity
         American Express Signature Variable Annuity
         American Express Signature One Variable Annuity
         Wells Fargo Advantage Variable Annuity
         Wells Fargo Advantage Builder Variable Annuity
         Post-Effective Amendment No. 5 to Registration Statement No. 333-65080
         on Form S-1

Ladies and Gentlemen:

I am familiar  with the  establishment  of the American  Enterprise  MVA Account
("Account"),  which is a separate account of American  Enterprise Life Insurance
Company ("Company") established by the Company's Board of Directors according to
applicable   insurance  law.  I  also  am  familiar  with  the  above-referenced
Registration  Statement  filed by the Company on behalf of the Account  with the
Securities and Exchange Commission.

I have made such  examination  of law and examined such documents and records as
in my judgment are necessary and  appropriate to enable me to give the following
opinion:

1.   The Company is duly  incorporated,  validly  existing and in good  standing
     under applicable state law and is duly licensed or qualified to do business
     in each  jurisdiction  where it  transacts  business.  The  Company has all
     corporate  powers  required  to carry  on its  business  and to  issue  the
     contracts.

2.   The  Account is a validly  created  and  existing  separate  account of the
     Company and is duly authorized to issue the securities registered.

3.   The  contracts  issued by the Company,  when offered and sold in accordance
     with  the  prospectus  contained  in  the  Registration  Statement  and  in
     compliance  with  applicable  law,  will be legally  issued  and  represent
     binding obligations of the Company in accordance with their terms.

I hereby consent to the filing of this opinion as an exhibit to the Registration
Statement.

Sincerely,




/s/ James M. Odland
- ----------------------
    James M. Odland
    Vice President and Group Counsel