Exhibit b(9)

                         OPINION AND CONSENT OF COUNSEL

Ladies and Gentlemen:

      I have made such examination of the law and have examined such company
records and documents as in my judgment are necessary or appropriate to enable
me to render the opinion expressed below:

      1. American International Life Assurance Company of New York is a valid
and existing stock life insurance company domiciled in the State of New York.

      2. Variable Account A is a separate investment account of American
International Life Assurance Company of New York validly existing pursuant to
the New York Insurance Laws and the Regulations thereunder.

      3. All of the prescribed corporate procedures for the issuance of the
Variable Annuity Contracts (the "Contracts") have been followed, and when such
Contracts are issued in accordance with the Prospectuses contained in the
Registration Statement, all state requirements relating to such Contracts will
have been complied with.

      4. Upon the acceptance of premiums made by Contract Owners pursuant to a
Contract issued in accordance with the Prospectuses contained in the
Registration Statement and upon compliance with applicable law, such Contract
Owner will have a legally-issued, fully-paid, nonassessable interest in such
Contract.

      This opinion, or a copy thereof, may be used as an exhibit to or in
connection with the filing with the Securities and Exchange Commission to the
Registration Statement on Form N-4 (File No. 333-63730) for the Contracts to be
issued by American International Life Assurance Company of New York and its
separate account, Variable Account A.


                                          /s/ Kenneth D. Walma
                                          --------------------------------------
                                          Kenneth D. Walma

Dated: May 1, 2002