American International Life Assurance
Company of New York
One Alico Plaza
P.O Box 667
Wilmington, DE 19899-0667
302 594-2987
March 29, 1999
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 submitted under Registration Number
33-90686.
Sincerely,
Edward Bacon
Director Variable Products 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 29, 1999
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 Nos. 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 Deferred Variable Annuity Contracts (the
"Contracts") 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 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 33-90686.
I hereby consent to the filing of this opinion with said Rule 24f-2 Notice.
Sincerely,
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
<TABLE>
<S> <C>
iscal period for which notice is filed 12/31/98
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, $2,232,725
1998
Aggregate sale price of accumulation units sold during the fiscal year ended
December 31, 1998 $2,232,725
Redemption of price of accumulation units redeemed during the fiscal year
ending December 31, 1998 $ 534,667
Total amount upon which fee calculation is based $1,698,058
Fee submitted (.000278) $ 472
</TABLE>
AMERICAN INTERNATIONAL LIFE ASSURANCE COMPANY OF NEW YORK
VARIABLE ACCOUNT B
BY HOWARD GUNTON
HOWARD GUNTON
SENIOR VICE PRESIDENT AND CHIEF FINANCIAL OFFICER
