Exhibit 7


           OPINION AND CONSENT OF CRAIG K. NORDYKE, F.S.A., M.A.A.A.,
                   EXECUTIVE VICE PRESIDENT AND CHIEF ACTUARY


                                                                   RE:  XX-XXXXX
                                        Prospectus (Joint and Last Survivor VUL)

Gentlemen:

In my capacity as Executive Vice President and Chief Actuary for Paragon Life
Insurance Company, I have provided actuarial advice concerning:  (a) the
preparation of a registration statement for Separate Account D filed on Form S-6
with the Securities and Exchange Commission under the Securities Act of 1933
(the "Registration Statement") regarding the offer and sale of flexible premium
variable life insurance policies (the "Policies"); and (b) the preparation of
policy forms for the Policies described in the Registration Statement.

It is my professional opinion that:

   1. The illustrations of cash values, death benefits, and accumulated premiums
      in the Appendix to the prospectuses 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
      premiums and benefits, as shown in the illustrations, appear to be more
      favorable to prospective purchasers of Policies aged 45 in the rate class
      illustrated than to prospective purchasers of Policies at other ages.

   2. 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 provisions 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.


                                    /s/
                                    Craig K. Nordyke, FSA, MAAA
                                    Executive Vice President and Chief Actuary