Pruco Life Insurance Company
213 Washington Street
Newark, New Jersey 07102
Ladies and Gentlemen:
In my capacity as Vice President and Corporate Counsel of Pruco Life Insurance Company ("Pruco Life"), I have reviewed the establishment of the Index Strategies Separate Account (the "Account") by the Executive Committee of the Board of Directors of Pruco Life Insurance Company as a non-insulated, non-unitized separate account for assets applicable to certain index-linked crediting strategy insurance contracts, pursuant to the provisions of Section 20-651 of the Arizona Insurance Code. I am responsible for oversight of the preparation and review of the Registration Statement on Form S-3, as amended, filed by Pruco Life with the Securities and Exchange Commission (Registration Number: 333-265507) under the Securities Act of 1933 for the registration of certain index-linked crediting strategy insurance contracts issued with respect to the Account.
I am of the following opinion:
(1) Pruco Life was duly organized under the laws 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.
(3) The index-linked crediting strategy insurance contracts are legal and binding obligations of Pruco Life 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/ Jordan K. Thomsen | | 10/3/2022 |
| Jordan K. Thomsen | | Date |
| Vice President and Corporate Counsel | | |