<Page>
                                     [LOGO]
                                  ASSURANT(R)

                           One Chase Manhattan Plaza
                               New York, NY 10005
                                 T 212.859.7000
                                www.assurant.com

April 29, 2011

Board of Directors
Union Security Life Insurance Company of New York
212 Highbridge Street, Suite D
Fayetteville, NY 13066

Re: Union Security Life Insurance Company of New York
    File no. 333-166461

Ladies and Gentlemen:

I am Secretary of 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. 1 to the Company's abovementioned Registration
Statement on Form S-1 (the "Registration Statement"). I am furnishing this
opinion letter to you at the Company's request to enable the Company to fulfill
the requirements of Item 16 of Form S-1 and Item 601(b)(5) of Regulation S-K of
the U.S. Securities and Exchange Commission (the "Commission"). In connection
with my opinion, I have examined such documents (including the Registration
Statement) and reviewed such questions of law as I considered necessary and
appropriate, and on the basis of such examination and review, it is my 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.   To my knowledge, the forms of the Contracts that will be issued by the
     Company have been filed in states where they are eligible for approval and,
     when issued as contemplated by the Registration Statement, the Contracts
     will be valid and binding obligations of the Company.

I have relied as to certain matters on information obtained from public
officials, officers of the Company, the administrator of the Contracts and other
sources belived by me to be responsible. 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 my 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. No opinion may be implied or inferred beyond
those expressly stated above. This opinion letter is rendered as of the date
hereof, and I have no obligation to update this opinion letter.

Sincerely,

/s/ Stephen W. Gauster
--------------------------------------------------
Stephen W. Gauster
Secretary
Union Security Life Insurance Company of New York