SEPARATE ACCOUNT A OF UNION SECURITY LIFE INS CO OF NEW YORK - FORM S-1 - EX-99.5 - May 3, 2010

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S-1 - S-1 - SEPARATE ACCOUNT A OF UNION SECURITY LIFE INS CO OF NEW YORKa09-34378_1s1.txt
EX-99.24 - EX-99.24 - SEPARATE ACCOUNT A OF UNION SECURITY LIFE INS CO OF NEW YORKa09-34378_1ex99d24.txt
EX-99.23(B) - EX-99.23(B) - SEPARATE ACCOUNT A OF UNION SECURITY LIFE INS CO OF NEW YORKa09-34378_1ex99d23b.txt
 



                                     [LOGO]
                                  ASSURANT(R)

                           One Chase Manhattan Plaza
                               New York, NY 10005
                                 T 212.859.7000
                                www.assurant.com

April 30, 2010

Board of Directors
Union Security Life Insurance Company of New York
212 Highbridge Street, Suite D
Fayetteville, NY 13066

Re:  Union Security Life Insurance Company of New York

Ladies and Gentlemen:

I have acted as corporate counsel to Union Security Life Insurance Company of
New York (the "Company"), a New York insurance company, in connection with the
registration of securities in the form of certain modified guaranteed annuities
(the "Contracts") under the Securities Act of 1933, as amended, pursuant to the
Company's Registration Statement on Form S-1 (the "Registration Statement"). I
am furnishing this opinion letter to you at the Company's request to enable the
Company to fulfill the requirements of Item 16 of the U.S. Securities and
Exchange Commission's (the "Commission") Form S-1 and Item 601(b)(5) of the
Commission's Regulation S-K. In connection with my opinion, I have examined such
documents (including the Registration Statement) and reviewed such questions of
law as I considered necessary and appropriate, and on the basis of such
examination and review, it is my opinion that:

1.   The Company is a corporation validly existing as a stock life insurance
     company under the laws of New York and is duly authorized by the Insurance
     Department of the State of New York to issue the Contracts (as defined in
     the Registration Statement).

2.   To my knowledge, the forms of the Contracts that will be issued by the
     Company have been filed in states where it is eligible for approval and
     upon issuance will be valid and binding obligations of the Company.

This opinion letter is provided to the Company for its use solely in connection
with the Registration Statement and may not be used, circulated, quoted or
otherwise relied upon by any other person or for any other purpose without my
express written consent, except that the Company may file a copy of this opinion
letter with the Commission as an exhibit to the Registration Statement. No
opinion may be implied or inferred beyond those expressly stated above. This
opinion letter is rendered as of the date hereof, and I have no obligation to
update this opinion letter.

Sincerely,

/s/ Raj B. Dave

Raj B. Dave
Assistant Secretary

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