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February 23, 1996
Securities and Exchange Commission
Attention: Filing Desk, Stop 1-4
450 Fifth Street, N.W.
Washington, D.C. 20549-1004
RE: Rule 24f-2 Notice for
IDS Life Variable Life Separate Account
File No. 811-4298 (2-97637/33-11165)
Commissioners:
[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, 1995
("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. $132,838,000*
[v] Amount of securities sold pursuant to 24f-2. $132,838,000
[vi] Fee $132,838,000 / 2900 equals $ 45,806.21
* Sales of $241,631,000 minus redemptions of $108,793,000
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/HSB/rdh
Enclosures<PAGE>
EXHIBIT INDEX
(b) (10) OPINION OF COUNSEL
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February 23, 1996
IDS Life Insurance Company
IDS Tower 10
Minneapolis, Minnesota 55440-0010
Gentlemen:
Reference is made to the Registration Statement on Form S-6 (File
Nos. 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 Notification for the fiscal year
ended December 31, 1995, I have made such examination of matter of
fact and law as I have deemed appropriate, and am of the opinion
that:
1) IDS Variable Life Separate Account, is a validly organized and
existing separate account of IDS Life Insurance Company duly
authorized, as a unit investment trust, under the laws of the
State of Minnesota, with the power and authority to issue and
sell the securities registered, and
2) The securities issued, being variable life insurance policies,
were legally issued, 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 Notification.
Sincerely,
Mary Ellyn Minenko
Attorney at Law
Minneapolis, MN 55440-0010
MEM/HSB/rdh
