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Richard H. Kirk Vice President, Corporate Counsel
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The Prudential Insurance Company of America 213 Washington Street, Newark, NJ 07102-2917 Tel 203-925-3707 richard.kirk@prudential.com |
April 20, 2026
VIA EDGAR
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
| Re: | Pruco Life Insurance Company |
| Post-Effective Amendment to Registration Statement on Form N-4 | |
| File Nos. 333-288845 |
Members of the Commission:
I have acted as counsel to Pruco Life Insurance Company (the “Company”) in connection with the filing of the Post-Effective Amendment to the above-referenced Registration Statement on Form N-4 under the Securities Act of 1933. Such Registration Statement relates to the contracts, riders, and endorsements (collectively, the “Contracts”) for the registered index-linked annuity to be sold through certain selling broker-dealers.
I have examined or caused to be examined such documents and reviewed or caused to be reviewed such questions of law as I considered necessary and appropriate for the purpose of rendering this opinion. In particular, I have reviewed the establishment of the Index Strategies Separate Account (the “Index Account”) by the Board of Directors of the Company as a non-insulated, non-unitized separate account for assets related to certain index-linked crediting strategies under the Contracts. On the basis of such examination and review, it is my opinion that:
(1) the Company is duly organized under the laws of the State of Arizona and is a validly existing corporation;
(2) the Index Account has been duly created and is validly existing as a non-unitized separate account pursuant to the provisions of the State of Arizona law; and
(4) the Contracts, when issued in accordance with the Registration Statements on Form N-4, will constitute legal, validly-issued and binding obligations of the Company.
I hereby consent to the filing of this opinion as an exhibit to the Registration Statements.
Sincerely,
| /s/ Richard H. Kirk | ||
| Richard H. Kirk | ||
| Vice President, Corporate Counsel |