EXHIBIT 9
OPINION OF EDWIN L. KERR
<PAGE>
January 12, 2001
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549
Re: Phoenix Home Life Variable Accumulation Account
Phoenix Home Life Mutual Insurance Company
Pre-Effective Amendment No. 1 to Form N-4
Registration Nos. 333-47862 and 811-03488
Dear Sirs:
As Counsel to the depositor, I have participated in the development of and
am familiar with the variable annuity, Phoenix Income Edge ("contract"),
which is the subject of the above-captioned registration statement on Form N-4.
In connection with this opinion, I have reviewed the contract, 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 contract.
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.
I further consent to the use of this opinion as an exhibit to the
above-captioned Registration Statement and to my being named as an expert under
"Experts" therein.
Very truly yours,
/s/ Edwin L. Kerr
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Edwin L. Kerr, Counsel
Phoenix Home Life Mutual Insurance Company
