Law Offices Greer, Herz & Adams, L.L.P. a registered limited liability partnership including professional corporations One Moody Plaza Galveston, Texas 77550 Galveston (409) 797-3200 Houston (713) 480-5278 Telecopier (409) 766-6424 April 30, 2010
Law
Offices
Xxxxx,
Xxxx & Xxxxx, L.L.P.
a
registered limited liability partnership
including
professional corporations
One Xxxxx
Plaza
Galveston,
Texas 77550
Galveston
(000) 000-0000
Houston
(000) 000-0000
Telecopier
(409) 766-6424
April 30,
2010
Securities
and Exchange Commission
000 Xxxxx
Xxxxxx, X.X.
Judicial
Plaza
Washington,
D.C. 20549
|
|
RE:
|
American
National Variable Life Separate Account ("Separate Account")
Post-Effective Amendment No. 15 to Form N-6; File No. 333-53122; Opinion
and Consent of Counsel
|
Gentlemen:
We are counsel to American National
Insurance Company ("ANICO"), the depositor of the Separate
Account. As such, we participated in the formation of the Separate
Account and the registration of such Separate Account with the Securities and
Exchange Commission. Accordingly, we are familiar with the corporate
records, certificates, and consents of officers of ANICO as we have deemed
necessary or appropriate for the purpose of this opinion.
Based upon the foregoing, and our
consideration of such other matters of fact and questions of law as we have
deemed necessary and proper in the circumstances, we are of the opinion
that:
1. ANICO
is a duly organized and existing corporation under the laws of the State of
Texas and that its principal business is to be an insurer.
2. The
Separate Account is a duly organized and existing separate account of ANICO
under the laws of the State of Texas and is registered as a unit investment
trust under the Investment Company Act of 1940.
3. The
Variable Life Contracts registered by this Registration Statement under the
Securities Act of 1933 and the Investment Company Act of 1940 (File No.
333-53122) will, upon issuance thereof, be validly authorized and
issued.
We hereby consent to the use of our
opinion of counsel in the Post-Effective Amendment to Form N-6 Registration
Statement (File No. 333-53122) filed on behalf of the Separate
Account. We further consent to the statements made regarding us and
to the use of our name under the caption "Legal Matters" in the statement of
additional information constituting a part of such Post-Effective Amendment to
such Registration Statement.
Yours very truly,
XXXXX, XXXX & XXXXX,
L.L.P.
Xxxxxxx X. Xxxxxxxx
