[QUARLES & BRADY LLP LETTERHEAD]


December 28, 1999


AAL Mutual Funds
Legal Department
222 West College Avenue
Appleton, WI 54914

Re: OPINION LETTER

Gentlemen:

         We are furnishing this opinion to you in connection with the filing of
Post-Effective Amendment No. 36 (the "Amendment") to the Registration Statement
on Form N-1A of The AAL Mutual Funds (the "Trust"), a Massachusetts business
trust which is registered with the Securities and Exchange Commission as a
series open-end management investment company under the Investment Company Act
of 1940 ("1940 Act"). This Amendment is being filed to amend and continue the
registration of an indefinite number of shares of beneficial interest, $0.01 par
value per share (the "Shares"), under the Securities Act of 1933("1933 Act").
The Trust has designated and offers its shares in the following series (each a
"Fund"):

                          The AAL Small Cap Stock Fund
                           The AAL Mid Cap Stock Fund
                           The AAL International Fund
                           The AAL Capital Growth Fund
                           The AAL Equity Income Fund
                              The AAL Balanced Fund
                          The AAL High Yield Bond Fund
                           The AAL Municipal Bond Fund
                                The AAL Bond Fund
                        The AAL Large Company Index Fund
                           The AAL Mid Cap Index Fund
                             The AAL Bond Index Fund
                            The AAL Money Market Fund
          The AAL U.S. Government Zero Coupon Target Fund, Series 2001
          The AAL U.S. Government Zero Coupon Target Fund, Series 2006



<PAGE>


         The Shares of each Fund, other than The U.S. Government Zero Coupon
Target Funds, Series 2001 and 2006, are further divided into three separate
classes, namely Class A Shares (Front End Sales Charge Shares), Class B Shares
(Contingent Deferred Sales Charge Shares) and Institutional Shares. The Shares
of the Target Funds consist only of Class A Shares.

         You have requested that we furnish you with the following opinion and
consent, which we understand is to be used in connection with, and filed as an
Exhibit to, the Amendment to the Trust's Registration Statement ("Registration
No. 33-12911")

         We understand that the Shares have been and will be offered to the
public in the manner and on the terms identified and referred to in the
Registration Statement. For 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 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,  which was initially filed with the Securities
     and Exchange  Commission  on March 26, 1987, as since amended and presently
     in effect,  and the Amendment to be filed on or about December 29, 1999, in
     which this opinion and consent letter is to be included as an exhibit.

2.   The  Declaration of Trust dated March 10, 1987,  filed with and approved by
     the  Secretary  of State,  Corporation  Division  for the  Commonwealth  of
     Massachusetts on March 15, 1987.

3.   A Certificate of the Secretary of the Commonwealth of Massachusetts,  dated
     a  recent  date,  certifying  the  status  of  the  Trust  as  a  voluntary
     association  possessing all powers recited in its  Declaration of Trust and
     authorized to transact business in the Commonwealth of Massachusetts.

4.   Minutes of meetings of the Board of Trustees of the Trust  establishing the
     various  series of Shares of the Trust and  Classes of Shares  within  such
     series, as recited above.

<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:

5.   The  Registration  Statement,  as amended  by the  Amendment,  becomes  and
     remains  effective,   and  each  Prospectus  and  Statement  of  Additional
     Information  constituting  a part of said  Registration  Statement and your
     Prospectus and Statement of Additional Information delivery procedures with
     respect thereto have fulfilled and will fulfill all the requirements of the
     1933 Act and the 1940 Act through all periods relevant to this opinion;

6.   All offers and sales of the Trust's  Shares have been and will be made in a
     manner complying with the terms of the Registration Statement;

7.   All  offers  and  sales  of the  Trust's  Shares  have  been and will be in
     compliance with the state securities laws of the states having jurisdiction
     thereof; and

8.   Each agreement,  obligation or contract  entered into by the Trust contains
     and will contain 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 Trust;

we are of the opinion that the issued and outstanding Shares of Trust are, and
the Shares of the Trust to be issued in the future will be, when so issued,
legal and validly issued, fully paid and non-assessable.

         We hereby consent to the filing of this opinion as an exhibit to the
Amendment to the Registration Statement.

                                                Very truly yours,

                                                /s/QUARLES & BRADY LLP

                                                QUARLES & BRADY LLP


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