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April 6, 2001

Metropolitan Life Separate Account UL
Metropolitan Life Insurance Company
One Madison Avenue
New York, NY 10010


Ladies and Gentlemen:

     In my capacity as Chief Counsel - Individual Business of Metropolitan Life
Insurance Company (the "Company"), I am rendering the following opinion in
connection with the filing with the Securities and Exchange Commission of an
amendment to the registration statement on Form S-6 (File No. 333-40161) under
the Securities Act of 1933. This Amendment to the Registration Statement is
being filed with respect to individual variable additional insurance options
issued by Metropolitan Life Separate Account UL (the "Account"). It is my
professional opinion that:

     1.  The Account is a separate investment account of the Company and is
         validly existing pursuant to the laws of the State of New York.


     2.  The Equity Options, when issued in accordance with the prospectus
         contained in the amendment to the Registration Statement and in
         compliance with applicable local law, are and will be legal and binding
         obligations of the Company in accordance with their terms; and


     3.  Assets attributable to reserves and other contract liabilities and held
         in the Account will not be chargeable with liabilities arising out of
         any other business the Company may conduct.

     In forming this opinion, I have made such examination of law and examined
such records and other documents as in my judgment are necessary and
appropriate.

     I hereby consent to the filing of this opinion letter as an exhibit to the
Registration Statement and to the use of my name under the caption "Legal,
Accounting and Actuarial Matters" in the prospectus contained in the
amendment to the Registration Statement.


                                        Very truly yours.


                                        Anne M. Goggin
                                        Chief Counsel - Individual Business