[Aetna logo] Aetna Inc. Financial Services 151 Farmington Avenue Hartford, CT 06156-8975 Michael A. Pignatella Counsel AFS Law, TS31 April 13, 2000 (860) 273-0261 Fax: (860) 273-9407 Securities and Exchange Commission 450 Fifth Street N.W. Washington, DC 20549 Re: Aetna Life Insurance and Annuity Company Post-Effective Amendment No. 4 to Registration Statement on Form S-2 Prospectus Title: Aetna Multi-Rate Annuity File No.: 333-49593 Dear Sirs: As Counsel of Aetna Life Insurance and Annuity Company (the "Company"), I have represented the Company in connection with the Aetna Multi-Rate Annuity (the "Multi-Rate Annuity"), a multi-rate interest option available under certain variable annuity contracts, and the Form S-2 Registration Statement relating to such account. In connection with this opinion, I have reviewed Post-Effective Amendment No. 4 to the Registration Statement on Form S-2 for the Multi-Rate Annuity, including the prospectus, and relevant proceedings of the Board of Directors. Based upon this review, and assuming the securities represented by the Multi-Rate Annuity are issued in accordance with the provisions of the prospectus, I am of the opinion that the securities, when sold, will have been legally issued, and will constitute a legal and binding obligation of the Company. I further consent to the use of this opinion as an exhibit to Post-Effective Amendment No. 4 to the Registration Statement. Sincerely, /s/ Michael A. Pignatella - ------------------------- Michael A. Pignatella Counsel