Exhibit 6


                                                                  April 24, 2001


The Prudential Insurance Company Of America
Prudential Plaza
Newark, New Jersey  07102-3277

Gentlemen:

This opinion is furnished in connection with the  registration by The Prudential
Insurance  Company of  America of  Prudential  Survivorship  Preferred  Variable
Universal Life Insurance  Contract (the "Contract")  under the Securities Act of
1933.  The  prospectus  included  in  the  Post-Effective  Amendment  No.  6  to
Registration  No.  33-61079 on Form S-6 describes the Contract.  I have reviewed
the  Contract  and I have  participated  in the  preparation  and  review of the
Registration Statement and Exhibits thereto. In my opinion:

1.       The  illustrations of cash surrender values and death benefits included
         in the  section  of the  prospectus  entitled  "Illustrations  of  Cash
         Surrender Values, Death Benefits, and Accumulated  Premiums",  based on
         the  assumptions  stated in the  illustrations  are consistent with the
         provisions of the Contract.  The rate structure of the Contract has not
         been  designed  so as to make the  relationship  between  premiums  and
         benefits,  as shown in the illustrations,  appear more favorable to the
         prospective  purchaser  of a  Contract  issued  on a male  age 55 and a
         female age 50, than to prospective purchasers of Contracts of different
         combinations of age, sex, or smoking status.

2.       The examples shown in the section of the prospectus  entitled "Changing
         the Type of Insurance Amount" are consistent with the provisions of the
         Contract.

3.       The examples  shown in the section of the  prospectus  entitled  "Death
         Benefit Guarantee" are consistent with the provisions of the Contract.

4.       The charts  included  in the  sections of the  prospectus  "How a Fixed
         Insurance  Amount  Contract's  Death  Benefit  Will  Vary"  and  "How a
         Variable  Insurance  Amount  Contract's  Death  Benefit  Will Vary" are
         consistent with the provisions of the Contract.

5.       The  deduction  in an  amount  equal  to  1.25%  of each  premium  is a
         reasonable  charge in  relation  to the  additional  income  tax burden
         imposed upon The Prudential  Insurance Company of America as the result
         of the  enactment  of Section  848 of the  internal  Revenue  Code.  In
         reaching that  conclusion,  a number of factors were taken into account
         that, in my opinion,  were  appropriate and which resulted in a project
         after-tax  rate  of  return  that  is  a  reasonable  rate  to  use  in
         discounting the tax benefit of the deductions allowed in Section 848 in
         taxable  years  subsequent  to the  year  in  which  the  premiums  are
         received.

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.

Very truly yours,



/s/ Andrew Ng
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Andrew Ng, FSA, MAAA
Actuarial Director
The Prudential Insurance Company of America