[Letterhead of American International Life Assurance Company of New York]
March 17, 2000
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
Ladies and Gentlemen:
Please note that the filing fee has been submitted under File Number 33-90686.
Sincerely,
/s/ Edward Bacon
Edward Bacon
Director Variable Products Accounting
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[Letterhead of American International Life Assurance Company of New York]
March 17, 2000
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
Ladies and Gentlemen:
I am General Counsel 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 Life 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 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
Vice President and General Counsel
<PAGE>
Rule 24f-2 Notice
For
AMERICAN INTERNATIONAL LIFE ASSURANCE COMPANY OF NEW YORK
VARIABLE ACCOUNT B
FILE NOS. 33-90686
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<S> <C>
Fiscal period for which notice is filed 12/31/99
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, $2,211,144
1999
Aggregate sale price of accumulation units sold during the fiscal year ended
December 31, 1999 $2,211,144
Redemption price of accumulation units redeemed during the fiscal year ending
December 31, 1999 $1,029,242
Total amount upon which fee calculation is based $1,181,902
Fee submitted (.000264) $ 312
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AIG LIFE INSURANCE COMPANY
VARIABLE ACCOUNT B
BY JOHN OEHMKE
/s/ John Oehmke
JOHN OEHMKE
VICE PRESIDENT AND CHIEF FINANCIAL OFFICER
