Principal
  Financial                                                Principal Life
  Group                                                    Insurance Company

July 20, 2001


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


Dear Sir or Madam:

In my capacity as Actuary of Principal Life Insurance Company ("Principal
Life"), I have provided actuarial advice concerning, and participated in the
design of Principal Life's 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 filling 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/Lisa Butterbaugh

Lisa Butterbaugh
Actuary
Phone:  515-248-3792
Fax:  515-362-0056



Mailing Address: Des Moines, Iowa USA 50392-0001 (515) 247-5111