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First Allmerica Financial Life Insurance Company
October 6, 2000
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
RE: ALLMERICA SELECT SEPARATE ACCOUNT OF FIRST ALLMERICA FINANCIAL LIFE
INSURANCE COMPANY
CIK No. 0000914285
REQUEST FOR WITHDRAWAL OF REGISTRATION STATEMENT ON FORM N-4
File No: 333-92117 Accession No: 0000912057-99-008249
Dear Sirs:
On December 3, 1999, the Allmerica Select Separate Account ("Registrant";
File No. 811-8116) of First Allmerica Financial Life Insurance Company
("First Allmerica") filed the above-referenced initial registration statement
(File No. 333-92117) on Form N-4 for certain flexible payment deferred
variable annuity contracts to be issued solely in New York. Concurrently,
First Allmerica submitted the proposed form of contract to the New York
Insurance Department for approval.
First Allmerica received comments from the Staff by letter from Mr. Kevin
McEnery dated January 31, 2000, but the registration statement has not yet
gone effective. However, following discussions with the New York Insurance
Department, First Allmerica has concluded that it is unlikely that the
Department will approve the contract form for the product in the foreseeable
future. First Allmerica therefore has determined that it is appropriate to
withdraw registration statement File No. 333-92117 at this time.
The Registrant hereby requests withdrawal of the registration statement on
Form N-4, File Number 333-92117, pursuant to Rule 477(a) under the Securities
Act of 1933.
If there are any questions concerning this request, please contact the
undersigned at 508-855-4194.
Sincerely,
/s/ Sheila B. St. Hilaire
Sheila B. St. Hilaire
Assistant Vice President and Counsel