Transamerica Occidental Life Insurance Company September 25, 2001 1150 S. Olive Street Los Angeles, CA 90015 Gentlemen: This opinion is furnished in connection with the filing by Transamerica Occidental Life Insurance Company of the initial Registration Statement on Form S-6 of its flexible premium variable life insurance policies ("Policies") allocated to the Transamerica Occidental Life Separate Account VUL-6 under the Securities Act of 1933. The prospectus included in the Registration Statement describes the Policies. I am familiar with and have provided actuarial advice concerning the preparation of the Registration Statement, including exhibits. In my professional opinion, the illustrations of death benefits and cash values included in Appendix C of the prospectus, based on the assumptions stated in the illustrations, are consistent with the provisions of the Policy. The rate structure of the Policies has not been designed so as to make the relationship between premiums and benefits, as shown in the illustrations of a prospective purchaser of a Policy for a male preferred nonsmoker, age 45, appear more favorable than prospective purchasers of Policies for people at other age/underwriting class combinations. I am also of the opinion that the aggregate fees and charges under the Policy are reasonable in relation to the services rendered, the expenses expected to be incurred, and the risks assumed by the Company. I hereby consent to the use of this opinion as an exhibit to the Initial Registration Statement. Sincerely, Kathy Shao, FSA, MAAA Second Vice President