Transamerica Occidental Life Insurance Company
December 4, 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 life insurance policies ("Policies")
allocated to the Transamerica Occidental Life Separate Account VUL-5 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 illustrations 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 preferred nonsmoker, age 45, 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
