April 25, 2003


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


RE:     American Enterprise MVA Account
        American Express Signature Variable Annuity(R)
        American Express(R) Signature One Variable Annuity
        American Express New Solutions(R) Variable Annuity
        American Express(R) Galaxy Premier Variable Annuity
        American Express Pinnacle Variable Annuity(SM)
        American Express FlexChoice(SM) Variable Annuity
        American Express Innovations Variable Annuity
        Evergreen Essential(SM) Variable Annuity
        Evergreen New Solutions Variable Annuity
        Evergreen Privilege(SM) Variable Annuity
        Evergreen Pathways(SM) Variable Annuity
        Wells Fargo Advantage Choice(SM) Variable Annuity
        American Express Innovations(SM) Classic Variable Annuity
        Wells Fargo Advantage(SM) Variable Annuity
        Wells Fargo Advantage(SM) Builder Variable Annuity
        Post-Effective Amendment No. 9 to Registration Statement No. 333-65080
        on Form S-2 to Form S-1 on Form S-2

Ladies and Gentlemen:

I am familiar with the above-referenced Registration Statement filed by American
Express MVA 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  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