Nancy H. Badeer
Head of Insurance Products Law
Associate General Counsel
285 Madison Avenue
New York, NY 10017
T: 980-949-3600
October 19, 2026
Board of Directors
Brighthouse Life Insurance Company
1209 Orange Street
Wilmington, DE 19801
| Re: | Opinion of Counsel |
| Pre-Effective Amendment No. 1 to the Registration Statement on Form S-3 |
| Brighthouse Life Insurance Company |
| File No. 333-297104 |
| Brighthouse SmartGuard Plus® |
Ladies and Gentlemen:
I am Head of Insurance Products Law and an Associate General Counsel in the Legal and Compliance
Department and provide legal counsel to the Brighthouse Life Insurance Company. This opinion is furnished in
connection with the proposed offering of a certain flexible premium adjusted index-linked life insurance policy (the
“Policy”) issued by Brighthouse Life Insurance Company (“Company”) under Pre-Effective Amendment No. 1 to
Registration Statement on Form S-3, File No. 333-297104, filed on or about October 19, 2026 (the “Registration
Statement”) and described therein, filed by the Company under the Securities Act of 1933, as amended.
I have made such examination of law and examined such records of the Company and other documents as in my
judgment are necessary or appropriate to render the opinion expressed below.
I am of the following opinions:
1. The Company is duly organized and exists under the laws of the State of Delaware and has been duly
authorized to do business and to issue life insurance policies by the Insurance Commissioner of the State of
Delaware.
2. The Policy covered by the above Registration Statement, and all amendments relating thereto, when
delivered and when the first premium payment made by an owner all in accordance with the prospectus (the
“Prospectus”) included in the Registration Statement and in compliance with the applicable local law, will be a
legal and binding obligation of the Company in accordance with its terms. Owners of the Policy, as such, will not
be subject to any deductions and charges by the Company other than those described in the Policy and as
referred to in the Prospectus.
I hereby consent to the use of this opinion letter, or a copy thereof, as an exhibit to the Registration Statement.
Sincerely,
/s/ Nancy H. Badeer
Nancy H. Badeer
Head of Insurance Products Law
Associate General Counsel