Exhibit 7.(a)(b)

                     Opinion and Consent of Peter E. Whipple





                                                          AMERITAS
                                                          Life Insurance Company
                                                          LOGO

June 16, 1999



Acacia National Life Insurance Company
7315 Wisconsin Avenue
Bethesda, MD 20814


Gentlemen:


This opinion is furnished in connection with the registration by Acacia National
Life Insurance  Company,  of a survivorship  flexible premium variable universal
life  insurance  policy  ("Contract")  under  the  Securities  Act of 1933.  The
prospectus  included in the  Registration  Statement on Form S-6  describes  the
Contract. The form of Contract was prepared under my direction and I am familiar
with  the  Registration  Statement  and  Exhibits  thereto.  This  contract  was
developed and filed under  Securities and Exchange  Commission Rule 6E-3(T),  as
interpreted at this time by the SEC staff. In my opinion:


   The  illustrations of death benefits and accumulation  values included in the
   section entitled "Illustrations of Death Benefits and Accumulation Values" in
   the  Appendices of the  prospectus,  based on the  assumptions  stated in the
   illustrations,  are consistent with the provisions of the Contract.  The rate
   structure  of  the  Contract  has  not  been  designed  so  as  to  make  the
   relationship  between premiums and benefits,  as shown in the  illustrations,
   appear more  favorable to  prospective  purchasers of the Contract for a male
   age 65 and a female age 65, than to  prospective  purchasers  of the Contract
   for other ages or for two males or two females.


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/Peter E. Whipple

Peter E. Whipple, FSA
Assistant Vice President and
Associate Actuary