EXHIBIT 8(m)
[LETTERHEAD OF XXXXX XXXX, SENIOR VICE PRESIDENT,
FIDELITY INVESTMENTS]
September 23, 2002
Xxxxxxx Xxxxx
Valley Forge Life Insurance Company
000 XXX Xxxxx
Xxxxxxxxx, XX 00000-0000
Re: VIP Funds Participation Agreement
Dear Xx. Xxxxx:
In response to your request, Fidelity Investments would like to provide the
following information in connection with the Participation Agreement(s) among:
Valley Forge Life Insurance Company ("Company"); Variable Insurance Product
Fund, Variable Insurance Product Fund II and Variable Insurance Product Fund III
("VIP Funds"); and Fidelity Distributors Corporation, underwriter for the VIP
Funds.
NAV Pricing. Fidelity Investments will comply with all applicable laws and
regulations in pricing shares of the VIP Funds. In particular, the Trustees of
the VIP Funds periodically review and approve Fidelity's practices and
procedures for addressing errors in pricing shares of any of the VIP Funds.
Fidelity believes that its practices and procedures conform with guidance from
the staff of the Securities and Exchange Commission regarding reprocessing of
transactions impacted by a pricing error. Of course, these practices and
procedures may be changed by Fidelity, with the approval of the Trustees, as
necessary or appropriate to conform to changes in applicable legal rules or to
serve the best interests of shareholders.
Under its current practices and procedures, Fidelity would report any material
error in the calculation or reporting of the VIP Funds' net asset value per
share to Company promptly upon discovery, and adjust the number of share
purchased or redeemed by the Separate Accounts to reflect the correct net asset
value per share.
We hope you will find this to be of assistance.
Sincerely,
/s/ Xxxxx Xxxx
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Xxxxx Xxxx
Senior Vice President, Risk Management
Fidelity Investments Institutional Services, Inc.
