January 7, 1998

Fortis Benefits Insurance Company
P. O. Box 64284
St. Paul, MN 55164

Dear Sirs:

This opinion is furnished in connection with the filing of the Registration
Statement on Form S-1 ("Registration Statement") by Fortis Benefits Insurance
Company ("Fortis") for general account interests pursuant to Flexible Premium
Deferred Annuity Contracts ("Contracts"). The Registration Statement covers a
proposed maximum aggregate offering price of $45,000,000. Purchase payments to
be received under the Contracts and allocated to the general account will be
held by Fortis in a non-unitized separate account with reserves established by
Fortis to support such Contracts.

The Contracts are designed to provide annuity benefits and are to be offered in
the manner described in the Prospectus which is included in the Registration
Statement.

The Contracts will be sold only in jurisdictions authorizing such sales.

I have examined all such corporate records of Fortis and such other documents
and laws as I consider appropriate as a basis for this opinion. On the basis of
such examination, it is my opinion that:

1.   Fortis is a corporation duly organized and validly existing under the laws
     of the State of Minnesota.

2.   The non-unitized separate account is established and maintained by Fortis
     pursuant to the laws of the State of Minnesota.

3.   When issued and sold as described above, the general account interests will
     be duly authorized and will constitute legal, validly issued and binding
     obligations of Fortis in accordance with the terms of the Contracts.

I hereby consent to the use of this opinion as an exhibit to the Registration
Statement and to the use of my name under the caption "Legal Matters" in the
Prospectus contained in the Registration Statement.

Sincerely,

/s/ David A. Peterson

David A. Peterson
Assistant General Counsel