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August 31, 2000
First Allmerica Financial Life Insurance Company
440 Lincoln Street
Worcester, MA 01653
RE: SEPARATE ACCOUNT SPVL OF FIRST ALLMERICA FINANCIAL
LIFE INSURANCE COMPANY
Gentlemen:
In my capacity as Assistant Vice President and Counsel of First Allmerica
Financial Life Insurance Company (the "Company"), I have participated in the
preparation of this Initial Registration Statement for the Separate Account
SPVL on Form S-6 under the Securities Act of 1933 with respect to the
Company's modified single premium variable life insurance policies.
I am of the following opinion:
1. The Separate Account SPVL is a Separate Account of the Company
validly existing pursuant to the Delaware Insurance Code and the
regulations issued thereunder.
2. The assets held in the Separate Account SPVL equal to the reserves
and other Policy liabilities of the Policies which are supported by the
Separate Account SPVL are not chargeable with liabilities arising out of
any other business the Company may conduct.
3. The individual modified single premium variable life insurance
policies, when issued in accordance with the Prospectus contained in the
Initial Registration Statement and upon compliance with applicable local
law, will be legal and binding obligations of the Company in accordance
with their terms and when sold will be legally issued, fully paid and
non-assessable.
In arriving at the foregoing opinion, I have made such examination of law and
examined such records and other documents as in my judgment are necessary or
appropriate.
I hereby consent to the filing of this opinion as an exhibit to this Initial
Registration Statement of the Separate Account SPVL on Form S-6 filed under the
Securities Act of 1933.
Very truly yours,
/s/ Sheila B. St. Hilaire
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Sheila B. St. Hilaire
Assistant Vice President and Counsel
