LOGO


AIG                       October 31, 2019

Life and Retirement
21650 Oxnard Street       U.S. Securities and Exchange Commission
Suite 750                 Division of Investment Management
Woodland Hills, CA 91367  100 F. Street, NE
www.aig.com               Washington, DC 20549

Manda Ghaferi             Dear Madam/Sir:

Vice President and        Referring to this Registration Statement on behalf
Deputy General Counsel    of American General Life Insurance Company Separate
T + 1 310 772 6545        Account VL-R ("Separate Account") and the
F + 1 310 772-6569        Registration Statement on Form N-6 filed November 4,
mghaferi@aig.com          2019 (the "Registration Statement") on behalf of the
                          Separate Account and having examined and being
                          familiar with the Articles of Incorporation and
                          By-Laws of American General Life Insurance Company
                          ("AGL"), the applicable resolutions relating to the
                          Separate Account and other pertinent records and
                          documents, I am of the opinion that:

                              1) AGL is a duly organized and existing stock
                                 life insurance company under the laws of the
                                 State of Texas;

                              2) The Separate Account is a duly organized and
                                 existing separate account of AGL;

                              3) Assets allocated to the Separate Account are
                                 owned by AGL and AGL is not a trustee with
                                 respect thereto. The variable universal life
                                 insurance policies provide that the portion
                                 of the assets of the Separate Account equal
                                 to the reserves and other variable universal
                                 life insurance policy liabilities with
                                 respect to the Separate Account will not be
                                 chargeable with the liabilities arising out
                                 of any other business AGL may conduct. AGL
                                 reserves the right to transfer assets of the
                                 Separate Account in excess of such reserves
                                 and other liabilities to the general account
                                 of AGL.

                              4) The variable universal life insurance
                                 policies being registered by the Registration
                                 Statement will, upon sale thereof, be duly
                                 authorized and constitute validly issued and
                                 binding obligations of AGL in accordance with
                                 their terms, except as enforceability may be
                                 limited by bankruptcy, insolvency,
                                 reorganization or similar laws affecting the
                                 rights of creditors generally.

                          I am admitted to the bar in the State of California,
                          and I do not express any opinion as to the laws of
                          any other jurisprudence. I hereby consent to the
                          filing of this opinion with the Securities and
                          Exchange Commission as an exhibit to the
                          Registration Statement.

                          Very truly yours,

                          /s/ Manda Ghaferi

                          Manda Ghaferi