February 25, 1997
Securities and Exchange Commission
Judiciary Plaza 450 Fifth Street NW
Washington, DC 20549
RE: Rule 24F-2 Notice for Composite Deferred Variable Account
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, 1996.
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. 648 Policies were sold during this period with aggregate premiums of
$18,698,133.*
V. 648 Policies were sold during the period with aggregate annual premiums of
$18,698,133.
Included hereto is an opinion of counsel as required. $5193.51 is being
submitted as payment of the filing fee, based upon aggregate premiums of
$15,061,203.
Sincerely,
/s/
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: $18,698,133
reduced by the difference between
(1) actual aggregate redemption price of
Composite Deferred Variable Account
securities redeemed during the fiscal
period: and, $3,636,930
(2) the acutal price of such redeemed
securities previously applied
pursuant to Rule 24e-2(a) under
Section 24(3)(1) 0 $3,636,930
-----------
$15,061,203
(c) registration fee pursuant to 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) $5193.51
<PAGE>
February 24, 1997
Securities and Exchange Commission
Judiaiary 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)
Dear Sir/Madam:
It is my opinion that the securities issued in accordance with the
captioned filing and which this Notice makes definite innumber were legally
issued and non-assessable. They were not fully paid, nowever, since the variable
annuity contracts issued in connection with the Composite Deferred Variable
Account contemplate the payment of additional premiums.
Very truly yours,
/s/
Brian F. Kreger
General Counsel
and Secretary
