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First Penn-Pacific Life Insurance Company
10 N. Martingale Road,
Schaumburg, IL 60173
December 19, 2000
Re: First Penn-Pacific Variable Life Insurance Separate Account
Gentlemen:
This opinion is furnished in connection with the filing by First Penn-Pacific
Life Insurance Company ("First Penn-Pacific"), on behalf of First Penn-Pacific
Variable Life Insurance Separate Account (the "Separate Account"), of
Post-Effective Amendment No. 1 ("PEA No. 1") to the Registration Statement on
Form S-6 (File No. 333-31116) with respect to First Penn-Pacific's Flexible
Premium Variable Universal Life Insurance Contract (the "Contract"). Premiums
received under the Contract may be allocated to the Separate Account. The
prospectus included in PEA No. 1 describes the Contracts. I am familiar with the
Contract provisions and with PEA No. 1.
It is my opinion that the hypothetical illustrations of death benefits, account
values, and surrender values included in PEA No. 1, based on the stipulated
rates of investment return and other assumptions stated in the hypothetical
illustrations, are consistent with the provisions of the Contract. The rate
structure of the Contracts has not been designed so as to make the relative
relationship between premiums and benefits, as shown in the illustrations,
appear more favorable to a prospective non-tobacco purchaser of a Contract aged
65 than to prospective purchasers of Contracts of other ages or underwriting
classes. The non-tobacco rate class generally has a more favorable rate
structure than other rate classes.
The current and guaranteed cost of insurance rates used in the illustrations
have not been designed so as to make the relationship between current and
guaranteed rates more favorable for the ages and sexes illustrated than for
non-tobacco prospective purchasers at other ages. The non-tobacco rate classes
generally have lower cost of insurance rates than the other rate classes. The
female rate classes generally have lower cost of insurance rates than the male
rate classes.
I hereby consent to the use of this opinion as an exhibit to PEA No. 1.
Sincerely,
/s/Mark Oberhellman
Mark Oberhellman, FSA, MAAA
