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February 25, 1994
Securities and Exchange Commission
450 Fifth Street, N.W.
Attn: Filing Desk, Stop 1-4
Washington, D.C. 20549-1004
RE: Rule 24f-2 Notice for
IDS Life Variable Life Separate Account
SEC File Nos. 2-97637/811-4298 and 33-11165/811-4298
Gentlemen:
[i] In accordance with the provisions of Rule 24f-2, IDS Life
Variable Life Separate Account hereby files its Rule 24f-2 Notice
for the fiscal year ended December 31, 1993 ("Fiscal Year").
[ii] Amount of securities registered other
than under 24f-2 which were unsold at
the beginning of the fiscal year $0
[iii] Amount of securities registered during
the fiscal year other than under 24f-2 $0
[iv] Amount of securities sold during the
fiscal year $71,555,000*
[v] Amount of securities sold pursuant to 24f-2 $71,555,000
[vi] Fee $71,555,000 X 0.00034483 equals $24,674.31
* Sales of $127,183,000 minus redemptions of $55,628,000
Enclosed please find an opinion of counsel.
If there are any questions, please contact the undersigned.
Very truly yours,
IDS LIFE VARIABLE LIFE SEPARATE ACCOUNT
Mary Ellyn Minenko
Counsel
(612) 671-3678
MEM/HB/rjf
Enclosures<PAGE>
EXHIBIT INDEX
(b) (10) OPINION OF COUNSEL
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February 25, 1994
IDS Life Insurance Company
IDS Tower 10
Minneapolis, MN 55440-0010
Gentlemen:
Reference is made to the Registration Statement of IDS Life Variable
Life Separate Account on Form S-6 (File No's. 2-97637 and 33-11165)
under the Securities Act of 1933 which became effective July 14, 1986,
and June 17, 1987, respectively, registering an indefinite amount of
securities pursuant to Rule 24f-2 adopted under The Investment Company
Act of 1940. In connection with the Rule 24f-2 Notice for the fiscal
year ended December 31, 1993, I have made such examination of matter of
fact and law as I have deemed appropriate, and am of the opinion that:
1) During the entire period covered by the Rule 24f-2 Notice, IDS
Life Account Variable Separate Account was a validly created
and existing separate account of IDS Life Insurance Company
duly authorized, as a unit investment trust, to issue and sell
the securities registered, and
2) The securities issued, being variable life insurance policies,
were legally issued and non-assessable and require no further
payment by the purchaser.
I hereby consent that the foregoing opinion may be used in connection
with the Rule 24f-2 Notice.
Sincerely,
Mary Ellyn Minenko
Attorney at Law
(612) 671-3678
MEM/HB/rjf
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