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                                                                      Exhibit 2B


The Manufacturers Life Insurance Company of New York
Corporate Center at Rye
555 Theodore Fremd Avenue
Rye, New York  10580





March 13, 1998


Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC  20549

Re:  Actuarial Opinion on Illustrations in Registration Statement

Dear Sirs:

This opinion is furnished in connection with the registration statement under
the Securities Act of 1933, as amended, of a flexible premium variable life
insurance policy (the "Policy") that will be offered and sold by The
Manufacturers Life Insurance Company of New York (the "Company").

The hypothetical illustrations of death benefits, contract values and surrender
values used in this registration statement are consistent with the provisions of
the Policy and the Company's administrative procedures. The rate structure of
the Policy has not been designed so as to make the relationship between premiums
and benefits, as shown in the illustrations, appear disproportionately more
favorable to a prospective purchaser of the Policy for the age and risk class
illustrated than for any other prospective purchaser. The particular
illustrations shown are for a commonly used risk class and for premium amounts
and ages appropriate to the markets in which the contract is sold.

I hereby consent to the use of this opinion as an exhibit to the Securities Act
Registration Statement on Form S-6.


Sincerely,

/s/ John G. Vrysen

John G. Vrysen
Chief Actuary