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[NEW YORK LIFE LETTERHEAD]
December 18, 2000
Re: New York Life Insurance and Annuity Corporation
Variable Universal Life Separate Account-I
Investment Company Act File Number: 811-07798
Securities Act File Number: 333-47728
Ladies and Gentlemen:
This opinion is furnished in connection with the referenced registration
statement filed by New York Life Insurance and Annuity Corporation ("NYLIAC")
under the Securities Act of 1933 (the "Registration Statement"). The prospectus
included in the Registration statement on Form S-6 describes single premium
variable universal life insurance policies (the "Policies") to be marketed under
the name "NYLIAC SPVUL". I am familiar with the Registration Statement and
Exhibits thereto.
In my opinion, the illustrations of benefits under the Policies included in the
Section entitled "Illustrations" in Appendix A of the prospectus, based on the
assumptions stated in the illustrations, are consistent with the provisions of
the respective forms of the Policies. The age selected in the illustrations is
representative of the manner in which the Policies operate.
In addition, I have reviewed the discount rate used in calculating the present
value of NYLIAC's future tax deductions resulting from the amortization of its
deduction for certain acquisition costs. In my opinion, the DAC tax charge is
reasonable in relation to NYLIAC's increased federal tax burden under section
848 resulting from the receipt of premiums; the targeted rate of return used in
calculating such charges is reasonable; and the factors taken into account by
NYLIAC in determining the targeted New York rate return are appropriate.
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I hereby consent to the use of this opinion as an exhibit to the Registration
Statement and to the reference to my name under the heading "Experts" in the
prospectus.
Sincerely,
/s/ MICHAEL FONG
Michael Fong, FSA, MAAA
Assistant Actuary
