EXHIBIT 9

                   CONSENT OF PAUL M. FISCHER, FSA, CLU, CHFC








                                                     November 3, 1997




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


Gentlemen:

         This opinion is furnished in connection with the registration of
flexible premium variable life insurance policies ("Policies") under the
Securities Act of 1933. The prospectuses included in the Registration Statement
on Form S-6 (SEC File No. 33-12989) describes the Policies. The forms of
Policies were prepared under my direction, and I am familiar with the
Registration Statement and Exhibits thereto.

         In my opinion, the illustrations of death benefits and cash values
included in the sections entitled "Illustrations of Death Benefits, Policy
Values ("Account Values"), and Cash Surrender Values" in Appendix B of the
prospectuses, based on the assumptions stated in the illustrations, are
consistent with the provisions of the respective forms of the Policies.

         I hereby consent to the use of this opinion as an exhibit to the
Registration Statement.

                                     Very truly yours,



                                     /s/ Paul M. Fischer
                                     Paul M. Fischer, FSA, CLU, ChFC
                                     Vice President