Jeffrey A. Proulx
Associate Counsel

Phone (612) 372-1810
Fax (612) 342-7531
Jeff.Proulx@RELIASTAR.COM



March 6, 1998


ReliaStar Life Insurance Company of New York
1000 Woodbury Road, Suite 102
Woodbury, NY 11797

Dear Sir/Madam:

In connection with the proposed  registration  under the Securities Act of 1933,
as amended,  of a survivorship  flexible  premium variable life insurance policy
(the  "Policy") and interests in ReliaStar  Life  Insurance  Company of New York
Variable  Life  Separate  Account I (the  "Variable  Account"),  I have examined
documents  relating to the establishment of the Variable Account by the Board of
Directors of our affiliated  company,  ReliaStar  Life Insurance  Company of New
York (the "Company"),  as a separate  account for assets  applicable to variable
contracts,  pursuant to New York Insurance Law Section 4240, as amended, and the
Registration  Statement,  on form S-6 (the "Registration  Statement") and I have
examined  such  other  documents  and have  reviewed  such  matters  as I deemed
necessary for this opinion, and I advise you that in my opinion:

         1.       The Variable Account is a separate account of the Company duly
                  created and validly existing pursuant to the laws of the State
                  of New York.

         2.       The Policy,  when  issued in  accordance  with the  Prospectus
                  constituting  a part of the  Registration  Statement  and upon
                  compliance  with  applicable  local  law,  will be  legal  and
                  binding  obligations  of the Company in accordance  with their
                  respective terms.

         3.       The portion of the assets held in the Variable  Account  equal
                  to reserves and other contract liabilities with respect to the
                  Variable Accounts are not chargeable with liabilities  arising
                  out of any other business the Company may conduct.

I consent  to the  filing of this  opinion  as an  exhibit  to the  Registration
Statement  and to the use of my name under the  heading  "Legal  Matters" in the
Prospectus  constituting  a  part  of  the  Registration  Statement  and  to the
references to me wherever appearing therein.

Sincerely yours,



Jeffrey A. Proulx
Associate Counsel

nysv_298/attyop (File 13757)