SEPARATE ACCOUNT VUL 4 OF TRANSAMER OCCIDENTAL LIFE INS CO
S-6, EX-99, 2000-10-05
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Transamerica Occidental Life Insurance Company
September 18, 2000
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 joint life insurance policies  ("Policies")
allocated to the  Transamerica  Occidental Life Separate Account VUL-4 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 illustration 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/female,  both preferred nonsmokers, ages 55/55,
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
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