Janet A. Nash
Attorney At Law
4500 Main Street, P.O. Box 418210
Kansas City, Missouri 64141-9210
Telephone (816)340-7480
Telecopier (816)340-4964
September 29, 2000
American Century Mutual Funds, Inc.
American Century Tower
4500 Main Street
Kansas City, Missouri 64111
Ladies and Gentlemen:
As counsel to American Century Variable Portfolios II, Inc., I am
generally familiar with its affairs. Based upon this familiarity, and upon the
examination of such documents as I have deemed relevant, it is my opinion that
the shares of the Corporation described in this initial statement on Form N-1A
to be filed with the Securities and Exchange Commission on or about September
29, 2000, will, when issued, be validly issued, fully paid and nonassessable.
For the record, it should be stated that I am an officer and employee
of American Century Services Corporation, an affiliated corporation of American
Century Investment Management, Inc., the investment advisor of American Century
Variable Portfolios II, Inc.
I hereby consent to the use of this opinion as an exhibit to the
initial statement.
Sincerely,
/s/Janet A. Nash
Janet A. Nash
