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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:
This opinion is furnished in connection with the filing by First Allmerica
Financial Life Insurance Company of a Initial 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 this Initial Registration Statement
describes the Policies. I am familiar with and have provided actuarial advice
concerning the preparation of this Initial 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
the incurred, and the risks assumed by the Company.
I hereby consent to the use of this opinion as an exhibit to the Initial
Registration Statement.
Sincerely,
/s/ Kevin G. Finneran
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Kevin G. Finneran, ASA, MAAA
Assistant Vice President and Actuary
