American International Life Assurance
Company of New York
One Alico Plaza
P.O. Box 667
Wilmington, DE 19899-0667
302 594-2987
March 30, 1998
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549
Re: American International Life Assurance
Company of New York
Variable Account B
File No . 33-90686
Gentlemen:
Please note that the filing fee has been remitted under Registration Number
33-90686.
Sincerely,
Edward Bacon /s/
- ----------------
Director Variable Accounting
<PAGE>
American International Life Assurance
Company of New York
One Alico Plaza
P.O. Box 667
Wilmington, DE 19899-0667
302 594-2987
March 30, 1998
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549
Re: American International Life Assurance
Company of New York
Variable Account B
File No . 33-90686
Gentlemen:
I am Associate General 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 Variable Life Insurance Policies (the
"Policies") of Variable Account B (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 Policies, 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 S-6 filed under
the Securities Act of 1933 as Registration Number 33-90686.
I hereby consent to the filing of this opinion with said Rule 24f-2 Notice.
Sincerely,
/s/Kenneth D. Walma
Kenneth D. Walma
Associate General Counsel
<PAGE>
Rule 24f-2 Notice
For
AMERICAN INTERNATIONAL LIFE ASSURANCE COMPANY OF NEW YORK
VARIABLE ACCOUNT B
FILE NOS. 33-90686
Fiscal period for which notice is filed 12/31/97
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, 1997 $ 2,019,297
Aggregate sale price of accumulation units sold during the fiscal year ended
December 31, 1997 $ 2,019,797
Redemption price of accumulation units redeemed during the fiscal year ending
December 31, 1997 $ 308,945
Total amount upon which fee calculation is based $ 1,710,852
Fee submitted (.000295) $ 505
AIG LIFE INSURANCE COMPANY
VARIABLE ACCOUNT B
BY HOWARD GUNTON
/s/Howard Gunton
HOWARD GUNTON
SENIOR VICE PRESIDENT AND CHIEF FINANCIAL OFFICER
