August 10, 1998





American Equity Investment Life Insurance Company
5000 Westown Parkway; Suite 440
West Des Moines, Iowa 50266

Gentlemen:



This opinion is furnished in connection with the registration by American Equity
Investment Life Insurance Company of a flexible premium variable life insurance
policy ("Policy") under the Securities Act of 1933, as amended.  The prospectus
included in Pre-Effective Amendment No. 2 to the Registration Statement on Form
S-6 (File No. 333-45815) describes the Policy.  I have provided actuarial advice
concerning the preparation of the policy form described in the Registration
Statement, and I am familiar with the Registration Statement and exhibits
thereto.



It is my professional opinion that:

(1)  The illustrations of death benefits and cash values included in Appendix A
     of the Prospectus, based on the assumptions stated in the illustrations,
     are consistent with the provisions of the Policy. 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 more favorable
     for policyowners at the ages illustrated than for policyowners at other
     ages.

(2)  The information contained in the examples set forth in Appendix B of the
     Prospectus, based on the assumptions stated in the examples, is consistent
     with the provisions of the Policy.

(3)  The fees and charges deducted under the Policy, in the aggregate, are
     reasonable in relation to the services rendered, the expenses expected to
     be incurred and the risks assumed by the insurance company.



I hereby consent to the use of this opinion as an exhibit to Pre-Effective
Amendment No. 2 to the Registration Statement and to the reference to my name
under the heading "Experts" in the Prospectus.



                              Sincerely,

                              /s/ Christopher G. Daniels

                              Christopher G. Daniels, FSA, MSAA
                              Consulting Actuary
                              American Equity Investment Life Insurance Company