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First Penn-Pacific Life Insurance Company
10 N. Martingale Road,
Schaumburg, IL 60173
May 30, 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
Pre-Effective Amendment No. 1 ("Amendment 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 Amendment No. 1 to the Registration Statement describes
the Contracts. I am familiar with the Contract provisions and with Amendment No.
1.
It is my opinion that the hypothetical illustrations of death benefits, account
values, and surrender values included in Amendment 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 Amendment No. 1.
Sincerely,
/s/ May Lee Low
May Lee Low, FSA, MAAA
