March 02 2000
Board of Directors
Canada Life of America Series Fund Inc.
330 University Avenue
Toronto Ontario
M5G 1R8
Canada
Gentlemen:
Re: Registration Statement No. 33-28888
This opinion is furnished in connection with the preparation and
filing by Canada Life of America Series Fund Inc. (The Fund)
with the Securities and Exchange Commission of a Notice
(Notice), dated March 02, 2000, as set forth in the Notice.
I call to your attention that as Senior Counsel U.S. Division for
The Canada Life Assurance Company, the parent of Canada Life
Insurance Company of America and Canada Life of New York, I
have general supervision of all legal affairs of Canada Life of
America Variable Annuity Account 1 (Variable Account 1). I
also have general supervision of legal affairs of The Fund, all of
whose shares are owned by the separate accounts of Canada
Life Insurance Company of America and Canada Life Insurance
Company of New York. This includes shares issued in the
amount of $504,935,460 the year ended December 31 1999.
Based upon my examination of the relevant documents contained
in The Funds registration statement, I am of the opinion that the
shares issued pursuant to The Funds prospectus are legally
issued fully paid and nonassessable. I consent to the filing of this
opinion, in conjunction with the Rule 24f 2 Notice, with the
Securities and Exchange Commission.
Sincerely
/s/ Charles H. MacPhaul
Charles H. MacPhaul
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U.S. SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM 24F-2
Annual Filing under Rule 24f-2
of the Investment Company Act of 1940
Read instructions at end of Form before preparing Form.
Please print or type.
1.
Name and address of issuer:
Canada Life Of America Series Fund, Inc., 330 University Avenue
Toronto, Ontario, Canada M5G 1R8
2.
The name of each series or class of securities for which this Form is
filed (leave this item blank if the Form is being filed for all series
and classes of securities of the issuer):
Money Market, Managed, Bond, Value Equity, Capital, International
Equity Series
3.
Investment Company Act File Number: 811-05816
Securities Act File Number : 33-28888
4(a).
Last day of fiscal year for which this Form is filed: December 31,
1999
4(b).
Check box if this Form is being filed late (i.e., more than 90 days
after the end of the issuers fiscal year).
Note: If the Form is being filed more than 90 days after the end of the
issuers fiscal year, interest must be paid on the registration fee due.
4(c).
Check box if this is the last time the issuer will be filing this form
5.
Calculation of registration fee:
(i)
Aggregate sale price of securities sold during the
fiscal year pursuant to section 24(f):
$509,880,348
(ii)
Aggregate price of securities redeemed or
repurchased during the fiscal year:
$503,329,166
(iii)
Aggregate price of securities redeemed or
repurchased during any prior fiscal year
ending no earlier than October 11, 1995 that
were not previously used to reduce
registration fees payable to the Commission:
$ N/A
(iv)
Total available redemption credits [add Items
5(ii) and 5(iii)]:
- - $503,329,166
(v)
Net sales - if item 5 (i) is greater than Item 5(iv)
[subtract Item 5(iv) from Item 5(i)]:
$ 6,551,182
(vi)
Redemption credits available for use in future
year - if Item 5(iv) is less than Item 5(iv)
[subtract Item 5(iv) from Item 5(i)]:
$( N/A )
(vii)
Multiplier for determining registration fee
(See Instruction C.8):
x .00026316
(viii)
Registration fee due [multiply Item 5(v) by item
5(vii)] (enter 0 if no fee is due):
= $ 1,724.00
6.
Interest due - if this Form is being filed more than 90 days after the
end of the issuers fiscal year (see Instruction D):
+$ N/A
7.
Total of the amount of the registration fee due plus any interest due
[Item 5(vii) plus Item 6]:
= $ 1,724.00
8.
Date the registration fee and any interest payment was sent to the
commissions lockbox depository: March 02, 2000
Account Number:
9108739
Method of Delivery:
X
Wire Transfer
Mail or other means
This Form has been signed below by the following persons on behalf of the
issuer and in the capacities and on the dates indicated.
BY (Signature and Title)
/s/ D.V. Rough
D.V. Rough
Treasurer
Date March 02, 2000.
Please print the name and title of the signing officer below the signature.
Attachment
(1)
(i)
Aggregate sale price of securities sold during the fiscal year in reliance
on rule 24f-2.
Series 001
- -Money Market Series
$482,731,661
Series 002
- -Managed Series
812,783
Series 003
- -Bond Series
9,269,073
Series 004
- -Value Equity Series
5,005,604
Series 005
- -Capital Series
5,213,489
Series 006
- -International Equity Series
1,902,850
$504,935,460
(2)
(ii)
Aggregate price of shares issued in connection with dividend
reinvestment plans.
Series 001
- -Money Market Series
$ 830,465
Series 002
- -Managed Series
1,391,926
Series 003
- -Bond Series
827,486
Series 004
- -Value Equity Series
777,050
Series 005
- -Capital Series
609,603
Series 006
- -International Equity Series
508,358
$ 4,944,888
(3)
(iii)
Aggregate price of shares redeemed or repurchased during the
fiscal year.
Series 001
- -Money Market Series
$475,375,143
Series 002
- -Managed Series
4,519,372
Series 003
- -Bond Series
8,989,815
Series 004
- -Value Equity Series
5,594,288
Series 005
- -Capital Series
6,495,565
Series 006
- -International Equity Series
2,354,983
$503,329,166
Shares Authorized
Shares Outstanding
Series 001
- -Money Market Series
20,000,000
2,049,688
Series 002
- -Managed Series
20,000,000
932,258
Series 003
- -Bond Series
10,000,000
1,620,220
Series 004
- -Value Equity Series
10,000,000
1,182,141
Series 005
- -Capital Series
20,000,000
493,051
Series 006
- -International Equity Series
10,000,000
512,081
5