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August 27, 1998


Securities and Exchange Commission
450 Fifth Street, N.W.
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 universal
life insurance contract (the "Contract") that will be offered and sold by The
Manufacturers Life Insurance Company of America.

The hypothetical illustrations of death benefits, contract values and surrender
values used in this registration statement are consistent with the provisions of
the Contract and the Company's administrative procedures. The rate structure of
the contract 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 contract 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,

Vic Bertolozzi

Vic Bertolozzi, FSA, MAAA
Actuary