COMPOSITE DEFERRED VARIABLE ACCT OF WM LIFE INSURANCE CO
24F-2NT, 1996-02-22
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February 22, 1996



Securities and Exchange Commission
Judiciary Plaza
450 Fifth Street NW
Washington DC  20549

RE:  Rule 24f-2 Notice for Composite Deferred Variable Account of
     WM Life Insurance Company Registration No. 33-11-11

Dear Sir/Madam:

I. The period for which this Notice is filed is from December 31, 1994 through
December 31, 1995

II. There were no securities  which had been registered under the Securities Act
of 1933 other than  pursuant to this  section but which  remained  unsold at the
beginning of the fiscal year.

III. There were no securities registered during such fiscal year other than
pursuant to this section.

IV. 525 Policies were sold during this period with aggregate premiums of
$12,289,742.32.*

V. 525 Policies were sold during the period with aggregate annual premiums of
$12,289,742.32.

Included hereto  is an  opinion  of  counsel  as  required.  $3331.56  is being
submitted  as payment of the  filing  fee,  based  upon  aggregate  premiums  of
$9,661,531.51.

Sincerely,



Charles W. Dishion \
Vice President
Treasurer and
Controller


*Pursuant to Rule 24f-2(c),  the filing fee accompanying  this Notice represents
one twenty-ninth of one (1) percent of the calculation following.
<PAGE>

(a) the actual aggregate sale price of
    Composite Deferred Variable Account 
    securities sold pursuant to Rule 
    24f-2 during the fiscal year                                  $12,289.742.32

    reduced by the difference between

    (1) actual aggregate redemption price of
        Composite Deferred Variable Account
        securities redeemed during the fiscal
        period; and,                             $2,628,210.81

    (2) the actual price of such redeemed
        securities previously applied pursuant 
        to Rule 24e-2(a) under Section
        24(3)(1).                                             0   $2,628,210.81 
                                                 ______________   ______________
                                                                   $9,661,531.51

(c) registration fee pursuant Section 6(b) of
    the Securities Act of 1933 (either one
    twenty-ninth of one percent of the result
    above or the minimum fee of ($100.00).            $3331.56


<PAGE>

February 21, 1996



Securities and Exchange Commission
Judiciary Plaza
450 Fifth Street, NW
Washington, DC  20549

RE:  Rule 24f-2 Notice for the Composite Deferred Variable Account of
     WM Life Insurance Company (Registration No. 33-11011)

Gentlemen:

It is my opinion that the securities issued in accordance with the captioned 
filing and which this Notice makes definite in number were legally issued and 
non-assessable.  They were not fully paid, however, since the variable annuity
contracts issued in connection with the Composite Deferred Variable Account 
contemplate the payment of additional premiums.

Very truly yours,



Brian F. Kreger
General Counsel
and Secretary


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