EXHIBIT (9)
Opinion of Counsel
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November 20, 2000
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549
Re: Phoenix Home Life Variable Accumulation Account
Phoenix Home Life Mutual Insurance Company
Post-Effective Amendment No. 1 to Form N-4
File Nos. 333-31320 and 811-8914
Dear Sirs:
As Counsel to the depositor, I have participated in the
development of and am familiar with the variable annuity, Phoenix
Retirement Planner's Edge for New York ("Contracts"), which is the
subject of the above-captioned Registration Statement on Form N-4/A.
In connection with the opinion, I have reviewed the Contracts,
the Registration Statement, the Charter and By-Laws of the company,
relevant proceedings of the Board of Directors, and the provisions of
New York insurance law relevant to the issuance of the Contracts.
Based upon this review, I am of the opinion that the
Contracts, when issued, will be validly issued, and will constitute a
legal and binding obligation of Phoenix Home Life Mutual Insurance
Company.
Very truly yours,
/s/ Edwin L. Kerr
Edwin L. Kerr, Counsel
Phoenix Home Life Mutual Insurance Company
