<PAGE>
December 20, 2000
First Allmerica Financial Life Insurance Company
440 Lincoln Street
Worcester, MA 01653
RE: SEPARATE ACCOUNT SPVL OF FIRST ALLMERICA FINANCIAL
LIFE INSURANCE COMPANY (FILE NOS. 333-45914/811-10133)
Gentlemen:
This opinion is furnished in connection with the filing by First Allmerica
Financial Life Insurance Company of a Post-Effective Amendment to the
Registration Statement on Form S-6 of its modified single premium variable life
insurance policies ("Policies") allocated to the Separate Account SPVL under
the Securities Act of 1933. The Prospectus included in the Post-Effective
Amendment to the Registration Statement describes the Policies. I am familiar
with and have provided actuarial advice concerning the preparation of this
Pre-Effective Amendment No. 1 to the Registration Statement, including exhibits.
In my professional opinion, the illustrations of death benefits and cash values
included in Appendix D of the Prospectus, based on the assumptions stated in
the illustrations, are consistent with the provisions of the Policy. The rate
structure of the Policies has not been designed so as to make the relationship
between premiums and benefits, as shown in the illustrations, appear more
favorable to a prospective purchaser of a Policy for a person age 55 or a
person age 65 than to prospective purchasers of Policies for people at other
ages or underwriting classes.
I am also of the opinion that the aggregate fees and charges under the Policy
are reasonable in relation to the services rendered, the expenses expected to
be incurred, and the risks assumed by the Company.
I hereby consent to the use of this opinion as an exhibit to the Post-Effective
Amendment to the Registration Statement.
Sincerely,
/s/ Paul T. Engeriser
Paul T. Engeriser, F.S.A., M.A.A.A.
Vice President and Actuary
