Exhibit 6

                                                                  April 24, 2001

The Prudential Insurance Company of America
213 Washington Street
Newark, New Jersey 07102-2992

To Prudential:

This opinion is furnished in connection with the  registration by The Prudential
Insurance  Company of America  of its  Variable  Universal  Life  Contract  (the
"Contract")  under  the  Securities  Act of 1933.  The  prospectus  included  in
Post-Effective  Amendment No. 3 to Registration  Statement No. 333-64957 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  Contracts.  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 a
          prospective   purchaser  of  a  Contract  for  male  age  35  than  to
          prospective  purchasers  of  Contracts  on males  of other  ages or on
          females.

     (2)  The examples shown in the section of the prospectus entitled "Changing
          the Type of Death Benefit" 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 Type A
          (Fixed)  Contract's  Death  Benefit  Will  Vary"  and  "How  a  Type B
          (Variable) 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, FSA, MAAA
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Andrew Ng, FSA, MAAA
Actuarial Director
The Prudential Insurance Company of America