EXHIBIT 5

                                                                     [LOGO]
                                                              Hartford Life
                    MICHAEL R. WINTERFIELD, FSA, MAAA  
                    Assistant Vice President           
                    Director, Individual Annuity Product Management


February 12, 1999



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

Dear Sir:

This opinion is furnished in connection with the Form S-6 Registration 
Statement under the Securities Act of 1933, as amended ("Securities Act"), of 
a certain modified single premium variable life insurance policy (the 
"Policy") that will be offered and sold by Hartford Life Insurance Company 
and certain units of interest to be issued in connection with the Policy.

The hypothetical illustrations of the Policy used in the Form S-6 
Registration Statement accurately reflect reasonable estimates of projected 
performance of the Policy under the stipulated rates of investment return, 
the contractual expense deductions and guaranteed cost-of-insurance rates, 
and utilize a reasonable estimation for expected fund operating expenses.

I hereby consent to the use of this opinion as an exhibit to the Form S-6 
Registration Statement  and to the reference to my name under the heading 
"Experts" in the Prospectus included as a part of such Form S-6 Registration 
Statement.

Very truly yours,

/s/ Michael Winterfield

Michael Winterfield, FSA, MAAA