EXHIBIT 7

                      OPINION AND CONSENT OF EDWIN L. KERR





                                                  May 15, 2000



Securities and Exchange Commission
450 Fifth Street, NW
Washington, D.C.  20549

Re:      PHLVIC Variable Universal Life Account
         PHL Variable Insurance Company
         Pre-Effective Amendment No. 1 to Form S-6
         Registration Nos. 333-65823 and 811-09065

Dear Sirs:

         As Counsel to the depositor, I have participated in the development of
and am familiar with the variable life insurance policy, Flex Edge Success
("Policy"), which is the subject of the above-captioned Registration Statement
on Form S-6.

         In connection with this opinion, I have reviewed the Policies, the
Registration Statement, the Charter and By-Laws of the company, relevant
proceedings of the Board of Directors, and the provisions of Connecticut
insurance law relevant to the issuance of the Policies.

         Based upon this review, I am of the opinion that the Policies, when
issued, will be validly issued, and will constitute a legal and binding
obligation of PHL Variable Insurance Company.

         My opinion is rendered solely in connection with the Registration
Statement and may not be relied upon for any other purposes without my written
consent. I hereby consent to the use of this opinion as an exhibit to such
Registration Statement, and to my being named under "Legal Matters" therein.

                                      Very truly yours,


                                      /s/ Edwin L. Kerr
                                      ---------------------------
                                      Edwin L. Kerr, Counsel
                                      Phoenix Home Life Mutual Insurance Company