<Page>
ALSTON&BIRD LLP
The Atlantic Building
950 F Street, NW
Washington, DC 20004-1404
202-756-3300
Fax: 202-756-3333
www.alston.com
DAVID J. BAUM DIRECT DIAL: 202 -756 -3346 E-MAIL: DAVID.BAUM@ALSTON.COM
April 21, 2008
Board of Directors
Union Security Life Insurance Company of New York
PO Box 3209
Syracuse, NY 13220
Re: Union Security Life Insurance Company of New York
File no. 333-14761
Ladies and Gentlemen:
We have acted as counsel to Union Security Life Insurance Company of New York
(the "Company"), a New York insurance company, in connection with the
registration of securities in the form of certain modified guaranteed annuities
(the "Contracts") under the Securities Act of 1933, as amended, pursuant to
Post-Effective Amendment No. 14 to the Company's Registration Statement on Form
S-1 (the "Registration Statement"). We are furnishing this opinion letter to you
at the Company's request to enable the Company to fulfill the requirements of
Item 16 of the Securities and Exchange Commission's (the "Commission") Form S-1
and Item 601(b)(5) of the Commission's Regulation S-K.
We have examined (i) the Amended and Restated Charter of the Company, (ii) the
Bylaws of the Company, (iii) an Insurance License from the Department of
Insurance of the State of New York, (iv) a Certificate of Good Standing from the
Department of Insurance of the State of New York, (v) records of proceedings of
the Board of Directors of the Company deemed by us to be relevant to this
opinion letter, (vi) state approvals of the forms of Contracts, (vii) the Annual
Statement of Separate Accounts of the Company, (viii) the Registration Statement
and (ix) other documents and agreements we deemed necessary for purposes of
expressing the opinions set forth herein. We also have made such further legal
and factual examinations and investigations as we deemed necessary for purposes
of expressing the opinions set forth herein.
As to certain factual matters relevant to this opinion letter, we have relied
conclusively upon originals or copies, certified or otherwise identified to our
satisfaction, of such other records, agreements, documents and instruments,
including certificates and statements of officers of the Company and of public
officials, as we have deemed appropriate as a basis for the opinions hereinafter
set forth. Except to the extent expressly set forth herein, we have made no
independent investigations with regard to matters of fact, and, accordingly, we
do not express any opinion as to matters that might have been disclosed by
independent verification.
This opinion letter is provided to the Company for its use solely in connection
with the Registration Statement and may not be used, circulated, quoted or
otherwise relied upon by any other person or for any other purpose without our
express written consent, except that the Company may file a copy of this opinion
letter with the Commission as an exhibit to the Registration Statement. The only
opinions rendered by us consists of those matters set forth in the sixth
paragraph hereof, and no opinion may be implied or inferred beyond those
expressly stated. This opinion letter is rendered as of the date hereof, and we
have no obligation to update this opinion letter.
<Page>
Our opinions set forth below are limited to the General Corporation and
Insurance Law of the State of New York. We do not express any opinion herein
concerning any other laws.
Based on the foregoing, it is our opinion that:
1. The Company is a corporation validly existing as a stock life insurance
company under the laws of New York and is duly authorized by the Insurance
Department of the State of New York to issue the Contracts.
2. The forms of the Contracts that will be issued by the Company have been
filed in states where it is eligible for approval and upon issuance will be
valid and binding obligations of the Company.
Sincerely,
ALSTON & BIRD LLP
By: /s/ DAVID J. BAUM
-----------------------------------
A Partner