EXHIBIT (K)

                               December 8, 2006

Metropolitan Life Separate Account UL
Metropolitan Life Insurance Company
200 Park Avenue
New York, NY 10166

Ladies and Gentlemen:

   In my capacity as Associate General Counsel 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 N-6 (File No. 333-131664) under the
Securities Act of 1933 and the Investment Company Act of 1940. 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 validly
       existing pursuant to the laws of the State of New York.

    2. The Advantage 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 consent to the filing of this opinion letter as an exhibit to the
Registration Statement.

                                          Very truly yours.

                                          /s/ Marie C. Swift
                                          Marie C. Swift
                                          Associate General Counsel