[Q&B LETTERHEAD]

Direct Dial: (414) 277-5677
E-Mail: caj@quarles.com

August 28, 1998


The AAL Mutual Funds
222 West College Avenue
Appleton, WI 54919

Gentlemen:

         In connection with the filing of Post-Effective Amendment No. 29 to the
registration  statement of the AAL Mutual Funds (the  "Fund"),  a  Massachusetts
business trust which is registered as a series  open-end  management  investment
company  under the  Investment  Company Act of 1940 (the "1940  Act"),  you have
requested that we furnish you with the following  opinion and consent  regarding
the legality of shares  offered by the Fund. We  understand  our opinion will be
used in  connection  with and filed as an  exhibit  to The  Fund=s  registration
statement  on  Form  N-1A  (the  "Registration  Statement"),  as  part  of  said
Post-Effective  Amendment  No. 29 which  will be filed with the  Securities  and
Exchange Commission on or about August 31, 1998.

         We understand that the shares have been, and continue to be, offered to
the public in the  manner and on the terms  identified  and  referred  to in the
Fund=s  Registration  Statement  and  all  amendments  thereto  filed  with  the
Securities and Exchange  Commission as  registration  number  33-12911 under the
Securities Act of 1933 (the "1933 Act") and file number  811-5075 under the 1940
Act. For the purposes of rendering this opinion,  we have examined  originals or
electrostatic  copies of such  documents as we considered  necessary,  including
those  listed  below.  In  conducting  such  examination,  we have  assumed  the
genuineness of all signatures and the authenticity of all documents submitted to
us as  originals  and the  conformity  to original  documents  of all  documents
submitted to us as copies.

         The documents we have examined are:

         1.       The Registration Statement and all amendments thereto;

         2.       The  Declaration  of Trust dated March 10, 1987, as filed with
                  the Office of the Secretary of State for the  Commonwealth  of
                  Massachusetts on March 13, 1987; and

         3.       Designations  of the Board of Trustees  of the various  series
                  and  classes of shares  offered by the Fund  during the fiscal
                  year ended April 30, 1998.



<PAGE>


         Based upon and subject to the foregoing,  after having given due regard
to such issues of law as we deemed relevant, and assuming that:

         1.       Each Prospectus  which is part of the  Registration  Statement
                  and your Prospectus  delivery  procedures with respect thereto
                  fulfilled  all the  requirements  of the 1933 Act and the 1940
                  Act throughout all periods relevant to this opinion;

         2.       All  offers  and  sales of the  Fund's  shares  were made in a
                  manner complying with terms of the Registration Statement;

         3.       All  offers  and  sales  of the  Fund=s  shares  were  made in
                  compliance  with  the  securities  laws of the  states  having
                  jurisdiction thereof; and

         4.       Each  agreement,  obligation  or contract  entered into by the
                  Fund contains a notice that the Declaration of Trust disclaims
                  personal  liability  of the  shareholders,  trustees and their
                  agents for payment under any credit extended to, contract with
                  or claim  against  the Fund.  We are of the  opinion  that the
                  Fund=s shares were when issued, legally issued, fully paid and
                  non-assessable.

         We hereby  consent  to the  filing of this  opinion  as an  exhibit  to
Post-Effective  Amendment No. 29 to the Registration  Statement to be filed with
the Securities and Exchange Commission on or about August 31, 1998.

                                                           Very truly yours,

                                                           /s/ Quarles & Brady

                                                           QUARLES & BRADY

CAJ:s2w
Enclosures