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                                                                    EXHIBIT 99.2


                           LEGAL OPINION AND CONSENT


April 27, 2001


ReliaStar Life Insurance Company of New York
20 Washington Avenue S.
Minneapolis, MN 55440

Dear Sir or Madam:

     In connection with the proposed registration under the Securities Act of
1933, as amended, of flexible premium variable life insurance policies (the
"Policies") and interests in ReliaStar Life Insurance Company of New York
Separate Account I (the "Variable Account"), I have examined documents relating
to the establishment of the Variable Account by the Board of Directors of
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 Mark 4240, as amended, and Pre-Effective Amendment
No. 2 to the Registration Statement, on Form S-6, File No. 333-52358 (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 Policies, 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.

     4.   Pre-Effective Amendment No. 2 does not contain disclosures that would
          render it ineligible to become effective under Rule 485(b) of the
          Securities Act of 1933.

     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
reference to me wherever appearing therein.

Sincerely,

/s/ Michael S. Fischer

Michael S. Fischer
Chief Counsel