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February 25, 1994
Securities and Exchange Commission
450 5th Street, NW
Attn: Filing Desk, Stop 1-4
Washington, D.C. 20549-1004
RE: Rule 24f-2 Notice for
IDS Life of New York Account SBS
SEC File No. 33-45776/811-6560
Gentlemen:
[i] In accordance with the provisions of Rule 24f-2, IDS Life of New
York Account SBS hereby files its Rule 24f-2 Notice for the fiscal
year ended December 31, 1993 ("Fiscal Year").
[ii] Amount of securities registered other
than under 24f-2 which were unsold at
the beginning of the fiscal year $0
[iii] Amount of securities registered during
the fiscal year other than under 24f-2 $0
[iv] Amount of securities sold during the
fiscal year $10,137,000*
[v] Amount of securities sold pursuant to 24f-2 $10,137,000
[vi] Fee $10,137,000 X 0.00034483 equals $3,495.54
* Sales of $10,350,000 minus redemptions of $213,000
Enclosed please find an opinion of counsel.
If there are any questions, please contact the undersigned.
Very truly yours,
IDS LIFE OF NEW YORK ACCOUNT SBS
Mary Ellyn Minenko
Counsel
(612) 671-3678
MEM/JDS/smb
Enclosures<PAGE>
EXHIBIT INDEX
(b) (10) OPINION OF COUNSEL
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February 25, 1994
IDS Life Insurance Company of New York
20 Madison Avenue Extension
Albany, New York 12203
Gentlemen:
Reference is made to the Registration Statement of IDS Life of New York
Account SBS on Form N-4 (File No. 33-45776) under the Securities Act of
1933 which became effective October 16, 1991 registering an indefinite
amount of securities pursuant to Rule 24f-2 adopted under The Investment
Company Act of 1940. In connection with the Rule 24f-2 Notice for the
fiscal year ended December 31, 1992, I have made such examination of
matter of fact and law as I have deemed appropriate, and am of the
opinion that:
1) During the entire period covered by the Rule 24f-2 Notice,
IDS Life of New York Account SBS, was a validly created and
existing separate account of IDS Life Insurance Company duly
authorized, as a unit investment trust, to issue and sell
the securities registered, and
2) The securities issued, being variable annuity contracts,
were legally issued and non-assessable and require no
further payment by the purchaser.
I hereby consent that the foregoing opinion may be used in connection
with the Rule 24f-2 Notice.
Sincerely,
Mary Ellyn Minenko
Attorney at Law
(612) 671-3678
MEM/JDS/smb
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