1

Exhibit #3





Gentlemen:

In my capacity as Senior Product Actuary for General American Life Insurance
Company, I have provided actuarial advice concerning a variable life
insurance product funded through General American Life Insurance Company
Separate Account 11.

It is my professional opinion that:

      1. The fees and charges deducted under the contract, in the aggregate,
         are reasonable in relation to the services rendered, the
         expenses expected to be incurred, and the risks assumed by the
         insurance company.

      2. The illustrations of cash values, death benefits, and accumulated
         premiums in the Appendix to the prospectus contained in the
         Registration Statement, are based on the assumptions stated
         in the illustration, and are consistent with the provisions
         of the Policies.  The rate structure of the Policies has not
         been designed so as to make the relationship between premium
         and benefits, as shown in the illustrations, appear to be
         more favorable to prospective purchasers of Policies aged 35
         and 50 in the rate class illustrated than to prospective
         purchasers of Policies at other ages.

      3. The information contained in the examples set forth in the section
         of the prospectus entitled "Death Benefits", is based on the
         assumption stated in the examples, and is consistent with the
         provision of the Policies.

I hereby consent to the filing of this opinion as an exhibit to the
Registration Statement and to the use of my name under the heading "Experts"
in the prospectus.




                                    Susan M. Benjamin, FSA, MAAA
                                    Senior Product Actuary