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October 29, 1999

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549

Re:  Actuarial Opinion on Illustrations Contained in Pre-Effective Amendment No.
     1 to a Registration Statement on Form S-6 (File No. 333-83023).

Dear Sirs:

This opinion is furnished in connection with the above-referenced registration
statement under the Securities Act of 1933, as amended, describing a flexible
premium variable universal 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, Policy 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 Policy 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/ BRIAN KOOP

Brian Koop, FSA, MAAA, FCIA
AVP & Pricing Actuary