February 26, 1997
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DE 20549
Re: American International Life Assurance Company of New York
Variable Account A
Registration Numbers 33-9144, 33-39170 and 33-58502
Gentlemen:
I am Assistant Secretary and Associate Counsel for American International
Life Assurance Company of New York (the "Company"), a New York stock life
insurance corporation. In connection with the offering of Deferred Variable
Annuity Contracts (the "Contracts") of Variable Account A (the "Account"),
a segregated investment account of the Company, I have examined such records
and documents and have made such further investigation and examination as I
deemed necessary for the purpose of this opinion.
It is my opinion that the Contracts, the registration of which is made
definite by the accompanying Rule 24f-2 Notice of the Account, were legally
issued, fully paid and non-assessable by the Account to the extent set forth
in the Account's prospectus forming part of its Registration Statement on Form
N-4 filed under the Securities Act of 1933 as Registration Numbers 33-9144,
33-39170 and 33-58502.
I hereby consent to the filing of this opinion with said Rule 24f-2 Notice.
Sincerely,
Kenneth D. Walma /s
__________________
Kenneth D. Walma
Assistant Secretary and Associate Counsel
KW/kr
Rule 24f-2
Notice For
AMERICAN INTERNATIONAL LIFE ASSURANCE COMPANY OF NEW YORK
ACCOUNT A
FILE NOS. 33-9144;33-39170 AND 33-58502
Fiscal period for which notice is filed
12/31/96
Securities registered and unsold at the beginning
of the fiscal year
0
Securities registered during this year other than
pursuant to Rule 24f-2
0
Sale price of accumulation units sold during fiscal
year ending December 31, 1996
$87,443,171
Aggregate sale price of accumulation units sold
during the fiscal year ending December 31, 1996
$87,443,171
Redemption price of accumulation units redeemed
during the fiscal year ending December 31, 1996
$9,614,659
Total amount upon which fee calculation is based
$77,828,513
Fee submitted (1/33 of 1% of total amount)
$23,585
AMERICAN INTERNATIONAL LIFE ASSURANCE COMPANY OF NEW YORK
VARIABLE ACCOUNT A
BY HOWARD GUNTON /s
__________________________
HOWARD GUNTON
VICE PRESIDENT AND COMPTROLLER
