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Exhibit 6
December 1, 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 Pre-Effective Amendment No.1 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
Pre-Effective Amendment No. 1 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
Pre-Effective Amendment No. 1 to the Registration Statement.
Sincerely,
/s/ Paul T. Engeriser
Paul T. Engeriser, F.S.A., M.A.A.A.
Vice President and Actuary
