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                                                                        [FORTIS]

April 4, 2002

Board of Directors
Fortis Benefts Insurance Company
576 Bielenberg Drive
Woodbury, MN  55125

RE:    EmPower Variable Annuity
       Fortis Benefits Insurance Company
       File No. 333-43805

Dear Sir/Madam:

This opinion is furnished in connection with the registration under the
Securities Act of 1933, as amended, of a certain Variable Annuity Contract (the
"Contract") that will be offered and sold by Fortis Benefits Insurance Company
(the "Company"). I have examined such documents (including the Form S-2
Registration Statement) and reviewed such questions of law as I considered
necessary and appropriate, and on the basis of such examination and review, it
is my opinion that:

1.     The Company is a corporation duly organized and validly existing as a
       stock life insurance company under the laws of Minnesota and is duly
       authorized by the Insurance Department of the State of Minnesota to issue
       the Contract.

2.     The form of the Contract that will be issued by the Company has been
       filed in states where it is eligible for approval and upon issuance will
       be valid and binding upon the Company.

I hereby consent to the use of this opinion as an exhibit to the Form S-2
Registration Statement and to the reference to my name under the heading "Legal
Opinions" in the prospectus included as a part of such Form S-2.

Sincerely,

/s/ Douglas R. Lowe

Douglas R. Lowe