EX-5 6 ex5-opinionofcounsel.htm EX-5 Document

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Richard H. Kirk
Vice President, Corporate Counsel



The Prudential Insurance Company of America
213 Washington Street, Newark, NJ 07102-2917
Tel 203-925-3707
richard.kirk@prudential.com
May 19, 2021

Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549

Re:    Prudential Annuities Life Assurance Corporation
Pre-Effective Amendment No. 1 to Registration Statement on Form S-3
File No. 333-252774

Members of the Commission:

In my capacity as Vice President and Corporate Counsel of The Prudential Insurance Company of America, I have reviewed the establishment of the Index Strategies Separate Account (the “Account”) by the Board of Directors of Prudential Annuities Life Assurance Corporation (“PALAC”) as a non-insulated, non-unitized separate account for assets applicable to certain index-linked crediting strategy annuity contracts, pursuant to the provisions of Section 20-651 of the Arizona Insurance Code. I was responsible for the oversight of the preparation and review of the Registration Statement on Form S-3 filed by PALAC in 2021 with the U.S. Securities and Exchange Commission under the Securities Act of 1933 for the registration of certain index-linked crediting strategy annuity contracts issued with respect to the Account.
I am of the following opinion:
(1) PALAC was duly organized under the laws of the State of Arizona and is a validly existing corporation;
(2) the Account has been duly created and is validly existing as a non-insulated, non-unitized separate account pursuant to the provisions of the State of Arizona law, and
(3) the index-linked crediting strategy annuity contracts are legal and binding obligations of PALAC in accordance with their terms.
In arriving at the foregoing opinion, I have made such examination of law and examined such records and other documents as I judged to be necessary or appropriate.
I hereby consent to the filing of this opinion as an exhibit to the Registration Statement.

Very truly yours,

/s/Richard H. Kirk
Richard H. Kirk
Vice President, Corporate Counsel