AAL VARIABLE LIFE ACCOUNT I
N-8B-2, 1997-07-10
Previous: AAL VARIABLE LIFE ACCOUNT I, N-8A, 1997-07-10
Next: AAL VARIABLE LIFE ACCOUNT I, S-6EL24, 1997-07-10



                                                    
As filed with the Securities and Exchange Commission on July 10, 1997.

                                                  Registration No. 811-_________


                       SECURITIES AND EXCHANGE COMMISSION
                            Washington, D.C.  20549


                                  FORM N-8B-2


REGISTRATION  STATEMENT OF UNIT  INVESTMENT  TRUSTS WHICH ARE CURRENTLY  ISSUING
SECURITIES Pursuant To Section 8(B) Of The Investment Company Act Of 1940

AAL Variable Life Account I
Name of Unit Investment Trust


x Not the issuer of periodic payment plan certificates
   Issuer of periodic payment certificates

                             Page 1 of 36 Pages

I.   ORGANIZATION AND GENERAL INFORMATION

1. (a)  Furnish  name of the trust and the  Internal  Revenue  Service  Employer
Identification Number.

AAL Variable Life Account I (the "Variable  Account").  The Variable Account has
no Internal Revenue Service employer identification number.

     (b)  Furnish title of each class or series of securities issued by the 
          trust.

AAL Variable Universal Life Certificate (the  "Certificate").  Units of interest
in the Variable Account provide benefits under a Certificate,  i.e. policy.  The
Variable  Account  Currently has five  subaccounts:  Money Market,  Bond,  Large
Company Stock,  Small Company Stock and Balanced.  Each subaccount  invests in a
corresponding  portfolio of The AAL Variable Product Series Fund, Inc. ("Fund").
Certificate owners may acquire interests in one or more of these subaccounts.

2. Furnish  name and  principal  business  address and ZIP code and the Internal
Revenue Service Employer Identification number of each depositor of the trust.

         Aid Association for Lutherans
         4321 North Ballard Road
         Appleton, Wisconsin  54919-0001
         EIN 39-0123480

3. Furnish  name and  principal  business  address and Zip Code and the Internal
Revenue Service Employer  Identification  Number of each custodian or trustee of
the trust  indicating for which class or series of securities  each custodian or
trustee is acting.

Aid  Association  for Lutherans  (the  "Company")  owns and will hold in its own
custody all of the securities issued through the Variable  Account.  There is no
custodian or trustee for the Variable Account.

<PAGE>


4. Furnish  name and  principal  business  address and Zip Code and the Internal
Revenue Service  Employer  Identification  Number of each principal  underwriter
currently distributing securities of the trust.

Distribution of the Certificate has not commenced.  When distribution commences,
the principal underwriter will be:

Name:  AAL Capital Management Corporation
Address:  222 West College Avenue
Appleton, WI  54919-0007
EIN:  39-1559375

5. Furnish name of state or other sovereign power, the laws of which govern with
respect to the organization of the trust.

Wisconsin

6. (a)  Furnish the dates of  execution  and  termination  of any  indenture  or
agreement  currently in effect under the terms of which the trust was  organized
and issued or proposes to issue securities.

AAL  Variable  Life  Account I was  established  by the  Company  as a  separate
investment  account  pursuant to  resolutions  of the Board of  Directors of the
Company  dated  May 8,  1997,  under  the laws of the  state of  Wisconsin.  The
resolutions authorize the issuance of the Certificate. The Variable Account will
continue in existence until its merger,  consolidation  or complete  liquidation
and the disposition of its assets according to law.

     (b) Furnish the dates of  execution  and  termination  of any  indenture or
agreement  currently  in effect  pursuant  to which the  proceeds of payments on
securities  issued or to be issued  by the  trust are held by the  custodian  or
trustee.

Not  applicable  for the  reasons  set forth in Item 3,  incorporated  herein by
reference.

7. Furnish in chronological order the following information with respect to each
change of name of the trust  since  January 1, 1930.  If the name has never been
changed, so state.

The Variable Account's name has never been changed.

8.   State the date on which the fiscal year of the trust ends.

December 31.

Material Litigation

9. Furnish a description of any pending legal proceedings, material with respect
to the security-holders of the trust by reason of the nature of the claim or the
amount thereof, to which the trust, the depositor,  or the principal underwriter
is a party or of which the assets of the trust are the  subject,  including  the
substance  of the  claims  involved  in such  proceeding  and the  title  of the
proceeding.   Furnish  a  similar   statement   with   respect  to  any  pending
administrative  proceeding  commenced  by a  governmental  authority or any such
proceeding  or legal  proceeding  known  to be  contemplated  by a  governmental
authority.   Include  any  proceeding  which,  although  immaterial  itself,  is
representative of, or one of, a group which in the aggregate is material.

<PAGE>


None.  The  Variable  Account  filed  its  registration  statement  on Form  S-6
contemporaneously with this form. N-8B-2

II.  GENERAL DESCRIPTION OF THE TRUST AND SECURITIES OF THE TRUST

General  Information  Concerning  the  Securities of the Trust and the Rights of
Holders

10.  Furnish a brief  statement  with respect to the following  matters for each
class or series of securities issued by the trust:

     (a) Whether the securities are of the registered or bearer type.

The  Certificates  are of the registered  type insofar as all  Certificates  are
personal  to the  respective  owners  of the  Certificates  ("Owners"),  and the
records concerning the Owners are maintained by or on behalf of the Company.

     (b) Whether the securities are of the cumulative or distributive type.

The Certificates  are of the cumulative  type,  providing for no distribution of
income,  dividends  or  capital  gain,  except in  connection  with  withdrawal,
surrender or payment of proceeds upon the death of the Insured.

    (c) The rights of security holders with respect to withdrawal or redemption.

Incorporated herein by reference is the prospectus (the "Prospectus") filed with
the Securities and Exchange Commission on June , 1997 by the Variable Account as
part of a  registration  statement,  as amended  from time to time,  on Form S-6
under  the  Securities  Act  of  1933  (the   "Registration   Statement")  filed
contemporaneously   with  this  Form  N-8(B)-2,   describing  the   Certificate,
specifically,   the  Section  "Access  to  Certificate   Value"   including  the
subsections "Partial Withdrawals," "Loans," and "Surrenders."

     (d) The rights of security  holders with respect to  conversion,  transfer,
partial redemption, and similar matters.

Incorporated  herein by reference are the following  Sections of the  Prospectus
for  the  Variable  Account  in  Exhibit  D:  "Access  to  Certificate   Value,"
specifically  the subsection,  "Partial  Withdrawals"  and "Investment  Options"
specifically,  the subsection  "Transfers" . Conversions are not permitted under
the Certificate,  but exchanges pursuant to section 1035 of the Internal Revenue
Code are permitted.

     (e) If the trust is the issuer of periodic payment plan  certificates,  the
substance of the provisions of any indenture or agreement with respect to lapses
or defaults or defaults by security  holders in making principal  payments,  and
with respect to reinstatement.

Incorporated  herein by reference is the following Section of the Prospectus for
the  Variable  Account in Exhibit D:  "Certificate  Summary"  specifically,  the
subsection "Certificate Termination."

<PAGE>


     (f) The  substance of the  provisions  of any  indenture or agreement  with
respect to voting  rights,  together  with the names of any  persons  other than
security  holders given the right to exercise  voting  rights  pertaining to the
trust's  securities or the underlying  securities and the  relationship  of such
persons to the trust.

Incorporated  herein by reference are the following  Sections of the  Prospectus
for the Variable Account in Exhibit D: "Investment Options,"  specifically,  the
subsection" Voting  Privileges," and "General  Information,"  specifically,  the
subsection "Membership."

     (g)  Whether security holders must be given notice of any change in:

          (1)  the composition of the assets of the trust.

Incorporated  herein by reference are the following  Sections of the  Prospectus
for the Variable  Account in Exhibit D: "Variable  Account" and "Rights Reserved
by AAL."  Except to the extent  described  in the  Prospectus,  no change in the
terms and  conditions of the  Certificates  can be made without notice to and/or
the consent of the Certificate Owners.


          (2)  the terms and conditions of the securities issued by the trust.

Notice  must be given to  Certificate  Owners  of any  change  in the  terms and
conditions of the Certificates. See the answer to Item 10 (h)(2) with respect to
the necessity of a consent by the Certificate Owners to such changes.

          (3)  the provisions of any indenture or agreement of the trust.

No  change  in  the  resolution  establishing  the  Variable  Account  or in any
agreement  relating to the manner in which it is operated  will be made  without
notice to Certificate  Owners if such change would adversely affect any right or
benefit to which they are entitled.

          (4)  the identity of the depositor, trustee or custodian.

The Variable  Account has no trustee or  custodian.  A change in the identity of
the depositor of the Variable  Account is prohibited  except by operation of law
upon a  merger  or  similar  reorganization  of AAL or  upon  assumption  of the
Certificate by another insurance  company,  both of which changes are subject to
state insurance department approval. In all events,  Certificate Owners would be
given notice of such assumption.

Incorporated  herein by  reference  for (1) through  (4) above is the  following
Section of the  Prospectus  for the  Variable  Account  in  Exhibit D:  "General
Information," specifically, the subsection "Rights Reserved by AAL."

(h) Whether  the consent of security  holders is required in order for action to
be taken concerning any change in:

          (1)  the composition of the assets of the trust.


<PAGE>


The consent of the  Certificate  Owners is not  required in order for Company to
invest the assets of the Variable Account in securities other than shares of the
portfolios  of the Fund as a substitute  for shares  already  purchased or as to
securities  that may be  purchased  in the future.  Such action will be taken in
compliance with applicable law (including any approval required by the SEC). The
consent  of  Certificate  Owners is not  required  in order for  Company to make
available,  subject to applicable  law,  additional  subaccounts of the Variable
Account investing in additional mutual funds.

          (2)  the terms and conditions of the securities issued by the trust.

The terms and conditions of a Certificate  cannot be changed without the consent
of the Certificate Owners.

          (3)  the provisions of any indenture or agreement of the trust.

See (g)(3) above which is incorporated herein by reference.

          (4)  the identity of the depositor, trustee or custodian.

See (g)(4) above which is incorporated herein by reference.

Incorporated  herein by  reference  for (1) through  (4) above is the  following
Section of the  Prospectus  for the  Variable  Account  in  Exhibit D:  "General
Information," specifically, the subsection" Rights Reserved by AAL."

     (i) Any other  principal  feature of the securities  issued by the trust or
any other principal  right,  privilege or obligation not covered by subdivisions
(a) to (g) or by any other item in this form.

Incorporated  herein by reference are the following  Sections of the  Prospectus
for the Variable  Account in Exhibit D: "Tax  Matters',  "General  Information,"
"Premiums," "Benefits," "Loans," "Charges," and "Cash Value."

Information Concerning the Securities Underlying the Trust's Securities

11.  Describe  briefly  the kind or type of  securities  comprising  the unit of
specified  securities in which security  holders have an interest.  (If the unit
consists  of a single  security  issued  by an  investment  company,  name  such
investment  company  and  furnish  a  description  of  the  type  of  securities
comprising the portfolio of such investment company.)
 .
The  Certificate  Owners do not own the securities of the portfolios of the Fund
in the  Variable  Account,  although  the value of those  securities  is used to
calculate benefits under a Certificate. The shares of the Fund described in Item
12, which is incorporated herein by reference, are owned by the Company and held
in the Variable  Account  pursuant to Wisconsin  insurance law which governs the
operation  of  separate  accounts  by  the  Company.  The  Fund  is an  open-end
diversified  management investment company organized as a "series" company under
the 1940 Act.

If the trust owns or will own any  securities of its regular  brokers or dealers
as defined in the 1940 Act, or their parents,  identify those brokers or dealers
and state the value of registrant's aggregate holdings of each subject issuer as
of the close of registrant's most recent fiscal year.

The Variable Account will own only shares of the portfolios of the Fund.

<PAGE>


12. If the trust is the issuer of periodic payment plan  certificates and if any
underlying  securities were issued by another  investment  company,  furnish the
following information for each such company:

     (a)  Name of company.

Item 1(b) is incorporated herein by reference.

     (b)  Name and principal business address of depositor.

Item 2 is incorporated herein by reference.

     (c)  Name and principal business address of trustee or custodian.

Not Applicable

     (d)  Name and principal business address of principal underwriter.

Item 4 is incorporated herein by reference.

     (e) The period  during which the  securities  of such company have been the
underlying securities.

Since the Variable  Account's  inception,  although no securities  have yet been
issued to the Variable Account.

Not applicable

Information Concerning Load, Fees, Charges and Expenses

13. (a)  Furnish  the  following  information  with  respect to each load,  fee,
expense or charge to which (1) principal  payments,  (2) underlying  securities,
(3) distributions,  (4) cumulated or reinvested distributions or income, and (5)
redeemed or liquidated assets of the trust's securities are subject:

(A) the nature of such load, fee, expense or charge;

(B) the amount thereof;

(C) the name of the person to whom such amounts are paid and his relationship to
the trust;

(D) the nature of the  services  performed by such person in  consideration  for
such load, fee, expense or charge.

 (1) With respect to principal  payments  and  subparagraphs  (A) through (D) of
this  sub-item,  see  "Certificate  Summary,"  and "Premiums and Charges" in the
Prospectus  for the  Variable  Account  in  Exhibit  D  incorporated  herein  by
reference.

(2) With respect to the  underlying  securities,  the following  information  is
responsive to sub-paragraphs (A) through (D) of this item.

The Prospectus for the Fund made available to Registrant discloses the following
expenses for each of the five portfolios of the Fund:

<PAGE>


The Fund pays advisory fees at an average  annual rate of 0.35% of the aggregate
average daily net assets of each portfolio up to $250 million,  and 0.30% on any
additional amounts.  With respect to each portfolio,  AAL has undertaken to keep
total Fund expenses to 0.35% for the year 1997. There are no 12b-1 fees.

(3) Not applicable. With respect to distributions and sub-paragraphs (A) through
(D) of this sub-item,  the response to Item 13(a)(1) is  incorporated  herein by
reference.

(4) With  respect  to  cumulated  or  reinvested  distributions  or  income  and
sub-paragraphs  (A) through (D) of this sub-item,  the response to Item 13(a)(1)
is incorporated herein by reference.

(5) With respect to redeemed or liquidated  assets and subparagraphs (A) through
(D) of this sub-item,  the response to Item 13(a)(1) is  incorporated  herein by
reference.

Incorporated  herein by reference are the following  Sections of the  Prospectus
for the Variable Account in Exhibit D: "Charges," and "Investment Options."

     (b) For each installment  payment type of periodic payment plan certificate
of the trust,  furnish the following  information with respect to sales load and
other deductions from principal payments. (Chart omitted)

Not  applicable.   The  Certificates  are  life  insurance   contracts  and  not
traditional  periodic payment plans. See the following Section of the Prospectus
for the  Variable  Account  in  Exhibit  D  incorporated  herein  by  reference:
"Charges."

     (c) State the amount of total  deductions as a percentage of the net amount
invested  for each type of security  issued by the trust.  State each  different
sales charge  available as a percentage  of the public  offering  price and as a
percentage  of the net  amount  invested.  List any  special  purchase  plans or
methods established by rule or exemptive order that reflect scheduled variations
in, or elimination of, the sales load; and identify each class of individuals or
transactions to which such plans apply.

See (a) and (b) above, which are incorporated herein by reference.  Also see the
following  Section  of the  Prospectus  for the  Variable  Account  in Exhibit D
incorporated herein by reference: "Charges."

     (d)  Explain  fully the reasons  for any  difference  in the price at which
securities  are  offered  generally  to the  public,  and  the  price  at  which
securities  are offered for any class of  transactions  to any class or group of
individuals,  including  officers,  directors,  or employees  of the  depositor,
trustee, custodian or principal underwriter.

               Not applicable. All Certificates will be offered to the public at
the same price.

     (e) Furnish a brief description of any loads, fees, expenses or charges not
covered in Item 13(a) which may be paid by security  holders in connection  with
the  trust  or  its  securities.  (Assignment,   reinstatement,  replacing  lost
certificates, etc.)

None.

<PAGE>


     (f) State  whether  the  depositor,  principal  underwriter,  custodian  or
trustee,  or any affiliated person of the foregoing may receive profits or other
benefits  not  included  in answer to Item  13(a) or 13(d)  through  the sale or
purchase of the trust's  securities  or  underlying  securities  or interests in
underlying securities,  and describe ties or interests in underlying securities,
and describe fully the nature and extent of such profits or benefits.

Neither  the  Company  nor any of its  affiliates  will  receive  any profits or
benefits  not  included in Item 13(a)  above.  The Company  will  reimburse  AAL
Capital  Management  Corporation  for  expenses  incurred in acting as principal
underwriter.  AAL Capital Management Corporation may enter into sales agreements
with  broker-dealers  to  solicit  for  the  sale  of the  Certificates  through
registered  representatives  who are  licensed to sell  securities  and variable
insurance products. The broker-dealers that enter into sales agreements with AAL
Capital  Management  Corporation  generally will receive  commissions based on a
percent of premiums  paid.  The writing agent will receive a percentage of these
commissions   from  the  respective   broker-dealer.   AAL  Capital   Management
Corporation will pay commissions to broker-dealers under a sales agreement,  who
will then be reimbursed by the Company for these  commissions.  In no event will
these  commissions be charged to the Owner. The basic  commissions  rates are as
follows:

 47% on the first target premium
 22% on the second target premium
 3% on all premiums

There are no trailing  commissions  although  the Company may pay an asset based
commission to registered representatives out of its own resources.

     (g) State the percentage  that the aggregate  annual charges and deductions
for  maintenance  and other  expenses  of the  trust  bear to the  dividend  and
interest  income  from the trust  property  during  the  period  covered  by the
financial statements filed herewith.

Not applicable.

Information Concerning the Operations of the Trust

14.  Describe  the  procedure  with  respect  to  applications  (if any) and the
issuance and authentication of the trust's  securities,  and state the substance
of the provisions of any indenture or agreement pertaining thereto.

Incorporated  herein by reference are the following  Sections of the  Prospectus
for the  Variable  Account in  Exhibit D:  "Certificate  Summary"  and  "General
Information" specifically, the subsection "Free Look."

15.  Describe  the  procedure  with  respect  to the  receipt of  payments  from
purchasers of the trust's  securities and the handling of the proceeds  thereof,
and  state  the  substance  of the  provisions  of any  indenture  or  agreement
pertaining thereto.

Premium payments must be made by check, money order or electronic payment.  Cash
is not accepted.  The initial  premium  payment may be made with the application
and given to a registered  representative of AAL Capital Management  Corporation
who will promptly forward the payment to the Company.  Thereafter,  premiums may
be paid to the Company at any time subject to any restrictions in a Certificate.
Incorporated  herein by reference are the following  Sections of the  Prospectus
for the Variable Account in Exhibit D: "Premiums" and "How to Receive Service."

<PAGE>


16.  Describe  the  procedure  with  respect to the  acquisition  of  underlying
securities  and  the  disposition  thereof,  and  state  the  substance  of  the
provisions of any indenture or agreement pertaining thereto.

Amounts  invested in a subaccount are promptly  invested in shares of the Funds.
Incorporated  herein by reference are the following  Sections of the  Prospectus
for the Variable  Account in Exhibit D:  "Premiums," and  "Investment  Options,"
"Cash Values" "Net Premiums" and "Allocations of Net Premiums."

17. (a) Describe the  procedure  with respect to  withdrawal  or  redemption  by
security holders.

Items 10(c) and 10(d) are incorporated  herein by reference.  Also  incorporated
herein  by  reference  are the  following  Sections  of the  Prospectus  for the
Variable  Account in Exhibit D:  "Access to  Certificate  Value,"  and  "General
Information"  specifically  the  subsection  "Free  Look," which  describes  the
procedures for exercising withdrawal, surrender and redemption rights.

     (b) Furnish the names of any persons who may redeem or  repurchase,  or are
required  to  redeem  or  repurchase,   the  trust's  securities  or  underlying
securities  from security  holders,  and the substance of the  provisions of any
indenture or agreement pertaining thereto.

Items 10(c), 10(d) and 17(a) are incorporated herein by reference.

     (c) Indicate whether repurchased or redeemed securities will be canceled or
may be resold.

No resale is  permitted.  Variable  Account  assets  are used to fund  insurance
benefits under the  Certificate  and there is no limit on the amount of Variable
Account assets that may be sold.

18. (a)  Describe  the  procedure  with  respect  to the  receipt,  custody  and
disposition of the income and other  distributable  funds of the trust and state
the  substance  of the  provisions  of any  indenture  or  agreement  pertaining
thereto.

All income and other  distributable  assets of the Variable Account are invested
in the portfolios of the Fund.  Distributions will be added to the assets of the
Variable Account. Incorporated herein by reference are the following Sections of
the  Prospectus  for the  Variable  Account in Exhibit D:  "Investment  Options"
specifically, the subsections "Variable Accounts" and "Charges."

     (b) Describe the  procedure,  if any, with respect to the  reinvestment  of
distributions  to security  holders and state the substance of the provisions of
any indenture or agreement pertaining thereto.

Not Applicable

     (c) If any  reserves  or  special  funds  are  created  out  of  income  or
principal,  state with  respect to each such  reserve  or fund the  purpose  and
ultimate disposition thereof, and describe the manner of handling of same.

Pursuant to state insurance law  requirements,  reserves are maintained to cover
obligations  arising from the  Certificates.  The assets in the Variable Account
attributable  to the  Certificates  are  part  of  these  reserves,  though  the
Certificate  Owners have no ownership  interest  therein and any excess reserves
would be for the benefit of the  depositor.  The  Company's  general  account is
available to satisfy  obligations  arising from the  Certificates.  Incorporated
herein  by  reference  are the  following  Sections  of the  Prospectus  for the
Variable Account in Exhibit D: Section "Investment Options,"  specifically,  the
subsections "Variable Account" and "Fixed Account."

<PAGE>


     (d) Submit a schedule showing the periodic and special  distributions which
have  been made to  security  holders  during  the three  years  covered  by the
financial  statements  filed  herewith.  State  for each such  distribution  the
aggregate amount and amount per share. If distributions  from sources other than
current  income have been made,  identify  each such other  source and  indicate
whether  such  distribution  represents  the  return of  principal  payments  to
security  holders.  If payments  other than cash were made,  describe the nature
thereof,  the account  charged and the basis of  determining  the amount of such
charge.

Not Applicable.  Certificates have not yet been sold.

19.  Describe the procedure  with respect to the keeping of records and accounts
of the  trust,  the making of  reports  and the  furnishing  of  information  to
security  holders,  and the  substance  of the  provisions  of any  indenture or
agreement pertaining thereto.

The Company maintains records and accounts for Certificate Owners and accounting
and financial records for the Variable Account. Incorporated herein by reference
is the following  Section of the Prospectus for the Variable  Account in Exhibit
D: "General Information" specifically, the subsection "Reports to Owners."

20.  State  the  substance  of the  provisions  of any  indenture  or  agreement
concerning the trust with respect to the following:

     (a)  Amendments to such indenture or agreement.

     (b)  The extension or termination of such indenture or agreement.

     (c) The removal or resignation of the trustee or custodian,  or the failure
of the trustee or custodian to perform its duties, obligations and functions.

     (d) The appointment of a successor trustee and the procedure if a successor
trustee is not appointed.

     (e) The  removal or  resignation  of the  depositor,  or the failure of the
depositor to perform its duties, obligations and functions.

     (f)  The  appointment  of a  successor  depositor  and the  procedure  if a
successor depositor is not appointed.

As to (a)  through  (f) to the  extent  relevant,  Items  10(g)  and  10(h)  are
incorporated herein by reference.

21. (a) State the substance of the provisions of any indenture or agreement with
respect to loans to security holders.

Incorporated  herein by reference is the following Section of the Prospectus for
the Variable Account in Exhibit D: "Access to Certificate Values"  specifically,
the subsection "Loans."

     (b) Furnish a brief  description  of any procedure or  arrangement by which
loans  are made  available  to  security  holders  by the  depositor,  principal
underwriter,  trustee or custodian,  or any affiliated  person of the foregoing.
The following items should be covered:


<PAGE>


    (1) The name of each person who makes such agreements or  arrangements  with
security holders.

   (2) The rate of interest payable on such loans.

   (3) The period for which loans may be made.

   (4) Costs or charges for default in repayment at maturity.

(5) Other material provisions of the agreement or arrangement.

Certificate  Owners may use the value of the Certificate for a loan and apply to
the Company for such loan, selecting the subaccount(s) and/or Fixed Account from
which the loan is taken.  The annual interest rate is 8% accruing daily from the
loan issue date  although a lower rate may apply to amounts taken from the Fixed
Account.  Once  Certificate  Anniversary  Date 15 is attained,  the rate will be
7.25%  Loans may  repaid  in full or part at any time . If the  total  loan ever
equals or  exceeds  the cash  value,  less any  Surrender  Charge, and the Death
Benefit  Guarantee is not in effect,  the  Certificate  will  terminate  without
value.  A  notice  will be sent  giving  31 days  to make  payment  to keep  the
Certificate  in  force.  Incorporated  herein  by  reference  are the  following
Sections of the  Prospectus  for the  Variable  Account in Exhibit D: "Access to
Certificate  Values"  specifically  the subsection  "Loans.  And "How to Receive
Service."

     (c) If  such  loans  are  made,  furnish  the  aggregate  amount  of  loans
outstanding at the end of the last fiscal year, the amount of interest collected
during the last fiscal year allocated to the depositor,  principal  underwriter,
trustee or custodian or  affiliated  person of the  foregoing  and the aggregate
amount  of loans  in  default  at the end of the last  fiscal  year  covered  by
financial statements filed herewith.

Not  applicable  because the  Variable  Account has yet to commence  operations.
Accordingly, no such loans have been made, no interest has been collected and no
loans are in default.

22. State the substance of the  provisions  of any  indenture or agreement  with
respect  to  limitations  on  the  liabilities  of  the  depositor,  trustee  or
custodian, or any other party to such indenture or agreement.

Incorporated  herein by reference are the following  Sections of the  Prospectus
for the Variable Account in Exhibit D: "General Information" and "Benefits."

23.  Describe  any bonding  arrangement  for  officers,  directors,  partners or
employees of the depositor or principal underwriter of the trust,  including the
amount of coverage and the type of bond.

A fidelity bond in the amount of $7 million covering the Company's  officers and
employees has been issued by Fidelity and Deposit Company of Maryland.


                                     
<PAGE>


24. State the  substance of any other  material  provisions  of any indenture or
agreement  concerning the trust or its securities and a description of any other
material  functions or duties of the depositor,  trustee or custodian not stated
in Item 10 or Items 14 to 23 inclusive.

None.

III. ORGANIZATION, PERSONNEL AND AFFILIATED PERSONS OF DEPOSITOR

Organization and Operations of Depositor

25. State the form or  organization  of the depositor of the trust,  the name of
the state or other  sovereign  power under the laws of which the  depositor  was
organized and the date of organization.

The Company is a fraternal  benefit society pursuant to section 501(c)(3) of the
Internal  Revenue  Code  organized  under the laws of the state of  Wisconsin in
1902.

26. (a) Furnish the following  information  with respect to all fees received by
the depositor of the trust in  connection  with the exercise of any functions or
duties  concerning  securities  of the trust  during the  period  covered by the
financial statements filed herewith. (Chart omitted)

Not applicable because no Certificates have been sold

     (b)  Furnish  the  following  information  with  respect  to any fee or any
participation  in fees received by the depositor from any underlying  investment
company or any affiliated person or investment adviser of such company.

   (1) The nature of such fee or participation.

   (2) The name of the person making payment.

     (3) The nature of the services  rendered in  consideration  for such fee or
     participation.

   (4) The aggregate  amount received during the last fiscal year covered by the
   financial statements filed herewith.

Not applicable because no Certificates have been sold

27. Describe the general  character of the business  engaged in by the depositor
including a statement  as to any  business  other than that of  depositor of the
trust.  If the  depositor  acts or has acted in any capacity with respect to any
investment company or companies other than the trust, state the name or names of
such company or companies,  their  relationship,  if any, to the trust,  and the
nature of the depositor's  activities therewith.  If the depositor has ceased to
act in such named capacity,  state the date of and circumstance surrounding such
cessation.

The Company  provides  fraternal  benefits and individual  insurance and annuity
products to its members with  membership  generally  available to Lutherans  and
their  families.  The Company does business in all 50 states and the District of
Columbia.


                                     
<PAGE>


Officials and Affiliated Persons of Depositor

28. (a) Furnish as at latest  practicable  date the following  information  with
respect to the depositor of the trust,  with respect to each officer,  director,
or partner of the depositor, and with respect to each natural person directly or
indirectly  owning,  controlling  or holding  with power to vote five percent or
more of the outstanding voting securities of the depositor.(Chart omitted)

Not  Applicable.  The Company is a fraternal  benefit  society  with each member
entitled to voting  privileges as set forth in its articles of incorporation and
by-laws.  All directors of the Company must be benefit  members which means that
each  will  own a  certificate  of  insurance.  No  directors  or  officers  own
Certificates because none have been issued.

(b) Furnish a brief  statement of the business  experience  during the last five
years of each officer, director or partner of the depositor.

Incorporated  herein by reference is the following Section of the Prospectus for
the  Variable  Account in Exhibit D:  "General  Information"  specifically,  the
subsection "Directors and Officers."

Companies Owning Securities of Depositor

29. Furnish as at latest practicable date the following information with respect
to each company which  directly or indirectly  owns,  controls or holds power to
vote five percent or more of the outstanding  voting securities of the depositor
(Chart omitted)

Not Applicable.

Controlling Persons

30. Furnish as at latest practicable date the following information with respect
to any person,  other than those covered by Items 28, 29, and 42 who directly or
indirectly controls the depositor.(Chart omitted)

None.

Compensation of Officers and Directors of Depositor, Compensation of Officers of
Depositor

31.  Furnish the  following  information  with respect to the  remuneration  for
services paid by the depositor  during the last fiscal year covered by financial
statements filed herewith: (Chart omitted)

     (a) directly to each of the officers or partners of the depositor  directly
receiving the three highest amounts of remuneration;

     (b)  directly  to all  officers or  partners  of the  depositor  as a group
exclusive of persons whose  remuneration  is included under Item 31(a),  stating
separately the aggregate  amount paid by the depositor  itself and the aggregate
amount paid by all the subsidiaries;

     (c) indirectly or through  subsidiaries to each of the officers or partners
of the depositor.


                                     
<PAGE>


With  respect  to (a),  (b) and (c)  above,  not  applicable.  No officer of the
Company  received any  remuneration  for services  rendered  with respect to the
Variable Account.

Compensation of Directors

32.  Furnish the  following  information  with respect to the  remuneration  for
services,  exclusive  of  remuneration  reported  under  Item  31,  paid  by the
depositor  during the last fiscal year  covered by  financial  statements  filed
herewith: (Chart omitted)

     (a)  the aggregate direct remuneration to directors;

     (b)  indirectly or through subsidiaries to directors.

With respect to (a) and (b) above,  not  applicable.  No director of the Company
received any  remuneration  for services  rendered  with respect to the Variable
Account.

Compensation to Employees

33. (a) Furnish the following  information  with respect to the aggregate amount
of  remuneration  for services of all employees of the  depositor  (exclusive of
persons  whose  remuneration  is  reported  in  Items  31 and 32)  who  received
remuneration  in excess of  $10,000  during  the last  fiscal  year  covered  by
financial   statements  filed  herewith  from  the  depositor  and  any  of  its
subsidiaries. (Chart omitted)

Not applicable.  The Variable Account has not commenced operations.

     (b) Furnish the following  information with respect to the remuneration for
services  paid  directly  during  the last  fiscal  year  covered  by  financial
statement filed herewith to the following classes of persons (exclusive of those
persons covered by Item 33(a)):  (1) Sales managers,  branch managers,  district
managers and other persons supervising the sale of registrant's securities;  (2)
Salesmen,  sales agents,  canvassers and other persons making  solicitations but
not in supervisory capacity; (3) Administrative and clerical employees;  and (4)
Others  (specify).  If a person is employed in more than one capacity,  classify
according to predominant type of work. (Chart omitted)

Not applicable.  The Variable Account has not commenced operations

Compensation to Other Persons

34. Furnish the following  information  with respect to the aggregate  amount of
compensation   for  services  paid  any  person   (exclusive  of  persons  whose
remuneration is reported in Items 31, 32 and 33), whose  aggregate  compensation
in connection with services rendered with respect to the trust in all capacities
exceeded  $10,000  during the last fiscal year covered by  financial  statements
filed herewith from the depositor and any of its subsidiaries. (Chart omitted)

Not applicable.  No other person received any remuneration for services rendered
with respect to the Variable Account .


                                     
<PAGE>


IV.  DISTRIBUTION AND REDEMPTION OF SECURITIES

Distribution of Securities

35.  Furnish the names of the states in which  sales of the trust's  securities:
(A) are currently  being made,  (B) are presently  proposed to be made,  and (C)
have been discontinued, indicating by appropriate letter the status with respect
to each state.

No sales of the  Certificates  yet have been made. The Company  anticipates that
the  Certificates may ultimately be offered in all 50 states and the District of
Columbia (see Item 27).

36. If sales of the trust's  securities  have at any time since  January 1, 1936
been  suspended  for more than a month  describe  briefly  the  reasons for such
suspension.

There have been no suspensions. Item 35 is incorporated herein by reference.

37. (a) Furnish the following  information  with respect to each instance  where
subsequent  to January  1, 1937,  any  federal  or state  governmental  officer,
agency,  or regulatory  body denied  authority to  distribute  securities of the
trust,  excluding  a denial  which was  merely a  procedural  step  prior to any
determination by such officer, etc. and which denial was subsequently rescinded.

          (1)  Name of officer, agency or body.

          (2)  Date of denial.

          (3)  Brief statement of reason given for revocation.

With respect to (1), (2) and (3), none.

     (b) Furnish the following  information  with regard to each instance where,
subsequent to January 1, 1937,  the  authority to  distribute  securities of the
trust has been revoked by any federal or state governmental  officer,  agency or
regulatory body.

With respect to (1), (2) and (3), none.

38.  (a)  Furnish  a  general  description  of the  method  of  distribution  of
securities of the trust.

Certificates  will be sold by Registered  Representatives  who are appropriately
licensed  employees of the Company and independent  contractors  with respect to
AAL Capital  Management  Corporation.  Incorporated  herein by  reference is the
following Section of the Prospectus for the Variable Account in Exhibit D:
"Distribution."

     (b) State the  substance  of any current  selling  agreement  between  each
principal  underwriter and the trust or the depositor,  including a statement as
to the  inception  and  termination  dates of the  agreement,  any  renewal  and
termination provisions, and any assignment provisions.

AAL Capital  Management  Corporation,  pursuant to an agreement with the Company
dated  November  23, 1994 and amended and restated  June 30,  1997,  acts as the
principal  underwriter  for  the  sale of the  Certificates.  The  Agreement  is
terminable  by either party upon 90 days prior written  notice  without costs or
penalties  assessed and can not be assigned  without the written  consent of the
other party. The Agreement provides that AAL Capital  Management  Corporation is
responsible for all securities related sales and marketing  activities  relating
to the Certificates, including all Securities and Exchange Commission, state and
NASD filing and other requirements.  AAL Capital Management  Corporation will be
reimbursed  by  the  Company  for  its  expenses   incurred  in  fulfilling  its
obligations under the Agreement.


                                     
<PAGE>

     (c) State the substance of any current  agreements or  arrangements of each
principal  underwriter  with  dealers,  agents,  salesman,  etc. with respect to
commissions and overriding commissions,  territories, franchises, qualifications
and  revocations.   If  the  trust  is  the  issuer  of  periodic  payment  plan
certificates, furnish schedules of commissions and the bases thereof. In lieu of
a statement concerning  schedules of commissions,  such schedules of commissions
may be filed as Exhibit A(3)(c).

See Items 38(a) and (b) above,  which are  incorporated  herein by reference.  A
schedule of commissions is filed as Exhibit A(3)(c) and is also  incorporated by
reference.

Information Concerning Principal Underwriter

39.  (a)  State  the  form of  organization  of each  principal  underwriter  of
securities of the trust,  the name of the state or other  sovereign  power under
the laws of which each underwriter was organized and the date of organization.

AAL Capital  Management  Corporation is a corporation that was organized in 1986
under Delaware law.

     (b)  State  whether  any  principal  underwriter   currently   distributing
securities  of the trust is a member of the National  Association  of Securities
Dealers, Inc.

AAL Capital  Management  Corporation is a member of the National  Association of
Securities Dealers, Inc.

40. (a) Furnish the following  information  with respect to all fees received by
each principal underwriter of the trust from the sale of securities of the trust
and any other functions in connection therewith exercised by such underwriter in
such capacity or otherwise during the period covered by the financial statements
filed herewith. (Chart omitted)

Not applicable because no Certificates have been sold.

     (b)  Furnish  the  following  information  with  respect  to any fee or any
participation in fees received by each principal underwriter from any underlying
investment  company  or any  affiliated  person or  investment  adviser  of such
company:

          (1)  The nature of such fee or participation.

          (2)  The name of the person making payment.

          (3)  The nature of the services rendered in consideration for such fee
                or participation.

          (4)  The aggregate amount received during the last fiscal year covered
               by the financial statements filed herewith.

With  respect to (1)  through  (4) above,  AAL  Capital  Management  Corporation
provides  certain  pricing and paralegal  services to the Fund and is reimbursed
for costs. AAL Capital  Management  Corporation also provides paralegal services
to the Company to assist the Company in providing  investment  advisory services
to the Fund.


                                     
<PAGE>


41. (a)  Describe  the  general  character  of the  business  engaged in by each
principal  underwriter,  including a statement as to any business other than the
distribution of securities of the trust. If a principal  underwriter acts or has
acted in any capacity with respect to any investment  company or companies other
than the  trust,  state the name or names of such  company or  companies,  their
relationship,  if any,  to the trust and the  nature  of such  activities.  If a
principal  underwriter has ceased to act in such named capacity,  state the date
of and the circumstances surrounding such cessation.

Incorporated  herein by reference is the following Section of the Prospectus for
the Variable Account in Exhibit D: "Distribution."

     (b) Furnish as at latest practicable date the address of each branch office
of each  principal  underwriter  currently  selling  securities of the trust and
furnish the name and residence address of the person in charge of such office.

Not applicable because no Certificates have been sold.

     (c) Furnish the number of individual salesmen of each principal underwriter
through whom any of the  securities of the trust were  distributed  for the last
fiscal year of the trust covered by the financial  statements filed herewith and
furnish the aggregate  amount of compensation  received by such salesmen in such
year.

Not  applicable.   No  Certificates  are  currently  being  distributed  by  the
underwriter or any of its representatives.

42. Furnish as at latest practicable date the following information with respect
to each principal underwriter currently distributing securities of the trust and
with respect to each of the officers, directors or partners of such underwriter.
(Chart omitted)

Not applicable because no Certificates are being distributed..

43. Furnish,  for the last fiscal year covered by the financial statements filed
herewith,  the  amount  of  brokerage  commissions  received  by  any  principal
underwriter  who is a  member  of a  national  securities  exchange  and  who is
currently distributing the securities of the trust or effecting transactions for
the trust in the portfolio securities of the trust.

Not applicable because no Certificates are being distributed

Offering Price or Acquisition Valuation of Securities of the Trust

44.  (a)  Furnish  the  following  information  with  respect  to the  method of
valuation  used by the trust for purposes of  determining  the offering price to
the  public of  securities  issued by the  trust or the  valuation  of shares or
interests  in the  underlying  securities  acquired  by the holder of a periodic
payment plan certificate:

          (1)  The source of quotations used to determine the value of portfolio
               securities.

The  underlying  securities  are valued at net asset  value as  supplied  by AAL
Capital Management Corporation personnel.

          (2)  Whether opening, closing, bid, asked or any other price is used.

Not applicable


<PAGE>


          (3)  Whether price is as of the day of sale or as of any other time.

          (4) A  brief  description  of  the  methods  used  by  registrant  for
determining  other  assets and  liabilities  including  accrual for expenses and
taxes (including taxes on unrealized appreciation).

          (5)  Other  items  which  registrant  adds to the net  asset  value in
computing offering price of its securities.

          (6)  Whether adjustments are made for fractions:

               (i)   before adding distributor's compensation (load); and

               (ii)  after adding distributor's compensation (load).

With  respect  to (3)  through  (6) above,  the  premiums  for the  Certificates
incorporate actuarial  considerations.  Variations in premiums reflect age, sex,
and risk class.  With respect to the Variable  Account,  incorporated  herein by
reference are the following  Sections of the Prospectus for the Variable Account
in  Exhibit  D:  "Investment  Options"  and "Cash  Value"  and  Section 6 of the
Certificate filed with the Securities and Exchange Commission  contemporaneously
by the Variable Account as Exhibit D to its registration  statement, on Form S-6
under the Securities Act of 1933 (the "Registration Statement")

        (b) Furnish a specimen  schedule  showing the components of the offering
   price of the  trust's  securities  as at the latest  practicable  date.  Such
   schedule shall be in substantially the following form:

(Note:  If  registrant  is an  issuer of  periodic  payment  plan  certificates,
furnish,  in lieu of such schedule an appropriate,  comparable  schedule showing
the acquisition price of the holders' interests in the underlying securities.)

   1. Value of portfolio securities

   2. Value of other assets

   3. Total (1 plus 2)

   4. Liabilities (include accrued expenses and taxes)

   5. Value of net assets (3 minus 4)

   6. Other charges

   (a) odd lot premiums

   (b) brokerage commissions

   (c) fees for administration

   (d) fees for custodian or trustee

   (e) fees for registrar or transfer agent

   (f) transfer taxes

   (g) reserves

   (h) others

   (i) total, 6(a) through 6(h), inclusive



                                  
<PAGE>


   7. Adjusted value of net assets (5 plus 6(i))

   8. Number of units outstanding

   9. Net asset value per unit (four decimals)

   (a) excluding other charges (5 divided by 8)

   (b) including other charges (7 divided by 8)

   10. Adjustment of 9(b) for fractions

   11. Adjusted net asset value per unit

   12. Offering price (show four decimals)

   (If any sales load is charged,  indicate amount, and apply percentage load to
   11 or other applicable base, indicating base.)

   13. Adjustment of 12 for fractions

   14. Offering price

   15. Accumulated undistributed income per unit (if not included in 3 and 9)

   16. Adjusted price (14 plus 15)

   17. Effective load per unit

   (a) In dollars (16 - [9(a) + 15])

   (b) In percentage (17(a) of [9(a) + 15])

(If  no  sales  load  is  charged  on   underlying   security  add   accumulated
undistributed  income per unit to sub-item 11, to show adjusted  offering price.
If any sub-items are inapplicable, answer "none.")

To the extent (b)  applies to the  Certificates,  the  response  to (a) above is
incorporated herein by reference.

     (c) If  there  is  any  variation  in the  offering  price  of the  trust's
securities  to any person or classes of persons other than  underwriters,  state
the nature and amount of such  variation  and  indicate the person or classes of
persons to whom such offering is made.

None.  See items  44(a) and 13(c)  and 13(d)  which are  incorporated  herein by
reference.  The premiums paid for each Certificate depend upon age, sex and risk
class.

45.  Furnish the  following  information  with respect to any  suspension of the
redemption  rights of the securities issued by the trust during the three fiscal
years covered by the financial statements filed herewith.

   (a) by whose action redemption rights were suspended.

   (b) the number of days' notice given to security  holders prior to suspension
of redemption rights.

   (c) reason for suspension.

(d) period during which suspension was in effect.

Not applicable.  There have been no such suspensions.

Redemption Valuation of Securities of the Trust


                                      
<PAGE>


46.  (a)  Furnish  the  following  information  with  respect  to the  method of
determining the redemption or withdrawal  valuation of securities  issued by the
trust:

          (1)  The source of quotations used to determine the value of 
               portfolio securities.

Item 44(a)(1) is incorporated herein by reference.

          (2)  Whether opening, closing, bid, asked or any other price is used.

Not Applicable

           (3)  Whether price is as of the day of sale or as of any other time.

          (4) A  brief  description  of  the  methods  used  by  registrant  for
determining  other  assets and  liabilities  including  accrual for expenses and
taxes (including taxes on unrealized appreciation).

          (5)  Other items which registrant deducts from the net asset value in 
computing redemption value of its securities: (Chart omitted)

          (6)  Whether adjustments are made for fractions.

As to  (3)  through  (6)  the  factors  involved  in  the  determination  of the
redemption or  withdrawal  value of the  Certificates  are not the usual factors
that apply to  securities.  See the Section of the  Prospectus  for the Variable
Account mentioned in item 44(a), which is incorporated herein by reference.

    (b) Furnish a specimen  schedule  showing the  components of the  redemption
   price to the holders of the trust's  securities as at the latest  practicable
   date. Such schedule shall be in substantially the following form:

   (Note:  If  registrant  is an issuer of periodic  payment plan  certificates,
   furnished  in lieu of such  schedule,  an  appropriate  comparable  schedule,
   showing the liquidation or redemption price of the security holder's interest
   in the underlying securities.)

   1. Value of portfolio securities

   2. Value of other assets

   3. Total (1 plus 2)

   4. Liabilities (include accrued expenses and taxes)

   5. Value of net assets (3 minus 4)

   6. Other charges

   (a) odd lot premiums

   (b) brokerage commissions

   (c) fees for administration

   (d) fees for custodian or trustee

   (e) fees for registrar or transfer agent

   (f) transfer taxes

   (g) reserves

   (h) others

   (i) total, 6(a) through 6(h), inclusive


                                      
<PAGE>


   7. Adjusted value of net assets (5 minus 6(i))

   8. Number of units outstanding

   9. Net asset value per unit (four decimals)

   (a) excluding other charges (5 divided by 8)

   (b) including other charges (7 divided by 8)

   10. Adjustment of 9(b) for fractions

   11. Adjusted net asset value per unit

   12. Redemption charge

   13. Adjusted redemption price

   14. Accumulated undistributed income per unit (if not included in 3 and 9)

   15. Actual redemption price (13 plus 14)

   16. Effective redemption fee per unit

   (a) in dollars ((9(a) + 14) - 15)

   (b) in percentage (16(a) of (9(a) + 14))

(If any sub-items are inapplicable, answer "none.")

  To the extent this  paragraph  applies,  see Items 44(a) and 46(a),  which are
incorporated herein by reference.

Purchase  and Sale of Interests in  Underlying  Securities  from and to Security
Holders

47. Furnish a statement as to the procedure with respect to the maintenance of a
position in the underlying securities or interests in the underlying securities,
the extent and nature  thereof  and the person who  maintains  such a  position.
Include  a  description  of  the  procedure  with  respect  to the  purchase  of
underlying  securities  or  interests in  underlying  securities  from  security
holders  who  exercise  redemption  or  withdrawal  rights  and the sale of such
underlying  securities  and  interests  in the  underlying  securities  to other
security  holders.  State  whether the method of  valuation  of such  underlying
securities or interests in underlying  securities differs from that set forth in
Items 44 and 46. If any item of expenditure included in the determination of the
valuation is not or may not actually be incurred or expended, explain the nature
of such item and who may benefit from the transaction.

There is no procedure  for the purchase of  underlying  securities  or interests
therein from Certificate  Owners who exercise surrender rights. The Company will
maintain  a position  in the Funds by (a)  purchasing  Fund  shares at net asset
value in connection with the net premiums  allocated to the Variable  Account in
accordance  with  instructions  from  Certificate  Owners and (b) redeeming Fund
shares at net asset  value for the purpose of meeting  Certificate  obligations.
See Item 16.


                                      
<PAGE>


V.   INFORMATION CONCERNING THE TRUSTEE OR CUSTODIAN

48.  Furnish the  following  information  as to each trustee or custodian of the
trust:

     (a)  Name and principal business address.

     (b)  Form of organization.

     (c) State or other  sovereign  power under the laws of which the trustee or
custodian was organized.

     (d)  Name of governmental supervising or examining authority.

The Company will act as custodian  and hold the assets of the Variable  Account.
The assets will be kept  physically  segregated and held separate and apart from
the  Company's  general  account.  The  Company  will  maintain  records  of all
purchases  and  redemptions  of shares of the  portfolios.  With  respect to (a)
through (d) above, Items 2 and 25 are incorporated herein by reference.

49.  State the basis for payment of fees or expenses of the trustee or custodian
for  services  rendered  with respect to the trust and its  securities,  and the
aggregate  amount  thereof for the last fiscal year.  Indicate the person paying
such fees or expenses.  If any fees or expenses are prepaid,  state the unearned
amount.

None. AAL will receive no remuneration for providing  custodial  services to the
Variable Account.

50. State whether the trustee or custodian or any other person has or may create
a lien on the assets of the trust, and if so, give full  particulars,  outlining
the  substance of the  provisions  of any  indenture  or agreement  with respect
thereto.

The Variable Account is currently divided into five subaccounts. Each subaccount
invests exclusively in shares of a single underlying portfolio of the Fund. Both
realized  and  unrealized  gains or losses  and  income  from the assets of each
subaccount  of the  Variable  Account are  credited to or charged  against  that
subaccount  without regard to income,  gains or losses from any other subaccount
of the Variable Account or from any other business the Company may conduct.

Obligations  to  Certificate  Owners  and  beneficiaries  that  arise  under the
Certificate are  obligations of the Company.  The Company owns the assets of the
Variable  Account.  Those  assets  will only be used to  support  variable  life
insurance  contracts and for any other  purposes  permitted by applicable  state
laws and regulations. The portion of the assets of the Variable Account equal to
the reserves and other contract liabilities with respect to the Variable Account
will not be charged  with  liabilities  that arise from any other  business  the
Company may  conduct.  The Company  may,  however,  transfer  from the  Variable
Account  to its  general  account  assets in excess  of the  reserves  and other
contract liabilities in respect of the Variable Account.

VI.  INFORMATION CONCERNING INSURANCE OF HOLDERS OF SECURITIES

51.  Furnish the following  information  with respect to insurance of holders of
securities:

     (a)  The name and address of the insurance company.

               The name and address of the Company are set forth in Item 2.

     (b)  The types of policies and whether individual or group policies.

The Certificates are individual variable universal life insurance policies.
     (c)  The types of risks insured and excluded.


                                      
<PAGE>


The Company  assumes the risk that the deductions made under the Certificate for
insurance  risks will prove  inadequate  to cover actual  insurance  costs.  The
Company also assumes the risk that deductions for expenses may be inadequate.

Incorporate  herein by reference is the following  Section of the Prospectus for
the  Variable  Account  in  Exhibit  D:  "Investment  Options  specifically  the
subsection "Variable Account."

     (d)  The coverage of the policies.

The amount of insurance coverage is stated in the Certificate.

     (e) The  beneficiaries  of such policies and the uses to which the proceeds
of policies must be put.

The beneficiary of insurance under a Certificate is either the Certificate Owner
or the Beneficiary specified in the Certificate,  who must be a person or entity
permitted  by  the  articles  and/or  bylaws  of  the  Company.   There  are  no
restrictions  on the use of the  proceeds  other than those  established  by the
Owner.

     (f)  The terms and manner of cancellation and of reinstatement.

Incorporated  herein by reference are the following  Sections of the  Prospectus
for the Variable Account in Exhibit D: "Cash Value" specifically, the subsection
"Surrender Value" and "General Information" specifically,  the subsections "Free
Look"  and  "Reinstatement"  and  "Certificate  Termination,"  specifically  the
subsections "Lapse" and "Death, Maturity and Surrender."

(g) The method of  determining  the amount of  premiums to be paid by holders of
securities.

Incorporated  herein by reference is the following Section of the Prospectus for
the Variable Account in Exhibit D: "Premiums,"

(h) The amount of aggregate  premiums paid to the insurance  company  during the
last fiscal year.

Not applicable.

     (i) Whether any person other than the insurance  company  receives any part
of such premiums, the name of each such person and the amounts involved, and the
nature of the services rendered therefor.

No person other than the Company  receives any part of the amounts  deducted for
assumption of mortality and expense risks.  Incorporated  herein by reference is
the following  Section of the Prospectus for the Variable  Account in Exhibit D:
"Charges."

     (j) The  substance of any other  material  provisions  of any  indenture or
agreement of the trust relating to insurance.

None.


                                      
<PAGE>


VII. POLICY  OF REGISTRANT

52. (a) Furnish the  substance of the  provisions  of any indenture or agreement
with respect to the  conditions  upon which and the method of selection by which
particular  portfolio  securities  must or may be eliminated  from assets of the
trust or must or may be replaced by other portfolio securities. If an investment
adviser or other  person is to be employed in  connection  with such  selection,
elimination or  substitution,  state the name of such person,  the nature of any
affiliation  to  the  depositor,   trustee  or  custodian,   and  any  principal
underwriter, and the amount of remuneration to be received for such services. If
any particular person is not designated in the indenture or agreement,  describe
briefly the method of selection of such person.

Incorporated  herein by reference is the following Section of the Prospectus for
the  Variable  Account in Exhibit D:  "General  Information"  specifically,  the
subsections "Rights and Privileges of AAL" and "Investment Options."

(b) Furnish the following information with respect to each transaction involving
the  elimination  of any  underlying  security  during the period covered by the
financial statements filed herewith.

   (1) Title of security.

   (2) Date of elimination.

   (3) Reasons for elimination.

   (4) The use of the proceeds from the sale of the eliminated security.

   (5) Title of security substituted, if any.

   (6) Whether  depositor,  principal  underwriter,  trustee or custodian or any
   affiliated person of the foregoing were involved in the transaction.

   (7)  Compensation  or  remuneration  received by each such person directly or
   indirectly as a result of the transaction.

 As to items (1) through (7), none.

     (c) Describe the policy of the trust with respect to the  substitution  and
elimination of the underlying securities of the trust with respect to:

          (1)  the grounds for elimination and substitution;

          (2)  the type of securities which may be substituted;

          (3) whether the acquisition of such substituted security or securities
would  constitute the  concentration  of investment in a particular  industry or
group of industries or would conform to a policy of  concentration of investment
in a particular industry or group of industries;

          (4)  whether such substituted securities may be the securities of 
another investment company; and

          (5) the  substance  of the  provisions  of any  indenture or agreement
which authorize or restrict the Certificate of the registrant in this regard (If
this subject has been entirely covered in Item 52(b), state "not applicable.")

Incorporated  herein by  reference  is the  Section  of the  Prospectus  for the
Variable  Account  in  Exhibit  D:  "General  Information"   specifically,   the
subsections: "Rights and Privileges of AAL" and "Investment Options."

     (d) Furnish a description of any policy  (exclusive of policies  covered by
paragraphs  (a) and (b)  herein)  of the  trust  which is  deemed  a  matter  of
fundamental policy and which is elected to be treated as such.

None.


                                      
<PAGE>


REGULATED INVESTMENT COMPANY

53.  (a)  State the taxable status of the trust.

Incorporated  herein by  reference  is the  Section  of the  Prospectus  for the
Variable Account in Exhibit D: "Tax Matters."

     (b)  State  whether  the trust  qualified  for the last  taxable  year as a
regulated  investment  company as defined in Section 851 of the Internal Revenue
Code  of  1954,   and  state  its  present   intention   with  respect  to  such
qualifications during the current taxable year.

Not applicable  because the Variable  Account is not a separate  taxable entity.
Incorporated  herein by  reference  to the  Section  of the  Prospectus  for the
Variable Account in Exhibit D: "Tax Matters."

VIII.   FINANCIAL AND STATISTICAL INFORMATION

54.  If the trust is not the  issuer  of  periodic  payment  plan  certificates,
furnish the  following  information  with respect to each class or series of its
securities. (Chart omitted)

Not  applicable  The  Variable  Account is deemed to be the  issuer of  periodic
payment plan securities.

55.  If the  trust is the  issuer  of  periodic  payment  plan  certificates,  a
transcript  of a  hypothetical  account  shall  be filed  in  approximately  the
following form on the basis of the  certificate  calling for the smallest amount
of payments.  The schedule shall cover a certificate of the type currently being
sold assuming that such  certificate had been sold at a date  approximately  ten
years  prior  to  the  date  of  registration  or at  the  approximate  date  of
organization of the trust. (Chart omitted)

Not applicable  because no Certificates  have been sold and the Variable Account
does not have an operating history.

56. If the trust is the issuer of periodic payment plan certificates, furnish by
years for the period  covered by the  financial  statements  filed  herewith  in
respect of certificates sold during each period,  the following  information for
each fully paid type and each installment  payment type of periodic payment plan
certificate currently being issued by the trust. (Chart omitted)

Not applicable because the Variable Account has not yet commenced operations.

57. If the trust is the issuer of periodic payment plan certificates, furnish by
years for the period  covered by the  financial  statements  filed  herewith the
following information for each installment payment type of periodic payment plan
certificate currently being issued by the trust. (Chart omitted)

Not applicable because no Certificates have been sold.

58. If the trust is the issuer of periodic  payment plan  certificates,  furnish
the following  information for each installment payment type of periodic payment
plan certificate out standing as at the latest practicable date.

Not applicable because no Certificates have been sold.
 .

                                      
<PAGE>


59.  Financial  Statements  shall be filed in accordance  with the  instructions
given below. (Instructions omitted):

Financial Statements of the Trust

The Variable  Account has not yet commenced  operations and,  therefore,  has no
assets or  liabilities,  has not received  any income or incurred any  expenses.
Accordingly, financial statements are not available at this time.

Financial Statements of the Depositor

The financial statements of Aid Association for Lutherans (AAL) will be provided
in a pre-effective amendment to the Registration Statement.

IX.  EXHIBITS

A.

(1)  Resolutions  of the Board of Directors  of Aid  Association  for  Lutherans
establishing the Variable Account.*

          (2)  Not applicable.

          (3)  Amended and Restated Principal Underwriting and Servicing 
               Agreement.*

          (4)  Not applicable.

          (5)  Form of Certificate*

          (6)  (a)  Articles of Incorporation of Aid Association for Lutherans*

                (b)  Bylaws of Aid Association for Lutherans*

                (c)  Schedules of Sales Commissions*

          (7)  Not applicable.

          (8)  Participation Agreement*

          (9)  Not applicable.

          (10) Certificate Application Form*

         B.       Not applicable.

         C.       Not applicable.

         D.  Prospectus  included  in Form  S-6  Registration  Statement  of AAL
Variable  Life  Account I filed  contemporaneously  with this Form  N-8B-2,  and
incorporated by reference herein.

* Incorporated by reference to the Variable Account's Registration Statement for
the Certificates.


                                      
<PAGE>


Pursuant  to the  requirements  of the  Investment  Company  Act  of  1940,  the
Depositor of the  Registrant has caused this  Registration  Statement to be duly
signed on behalf of the  Registrant  in the City of  Appleton,  and the State of
Wisconsin on the 26th day of June, 1997.

                           AAL Variable Life Account I
                              (Name of Registrant)

                        By: Aid Association for Lutherans
                               (Name of Depositor)
                                     [Seal]

                            By: /s/ John O. Gilbert,

                           Typed Name: John O. Gilbert


Attest:  /s/ Woodrow E. Eno
                  Woodrow E. Eno








© 2022 IncJournal is not affiliated with or endorsed by the U.S. Securities and Exchange Commission