SEPARATE ACCOUNT VA-P OF FIRST ALLMERICA FIN LIFE INSUR CO
NSAR-U, 1999-04-05
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FORM N SAR
SEMI-ANNUAL REPORT
FOR REGISTERED INVESTMENT COMPANIES

Report for six month period ending: // (a)

or fiscal year ending:  12/31/98

ls this a transition report? (Y/N) N

Is this an amendment to a previous filing? (Y/N) Y

Those items or sub-items with a box " / " after the item number
should be completed only if the answer has changed from the
previous filing on this form.
1A. Registrant Name:  First Allmerica Financial Life Insurance
Company                                 VA-P
  B. File Number: 8 l l-8872

  C. Telephone Number:  508-855-6982

2.A. Street: 440 Lincoln Street
   B. City: Worcester    C. State:  MA  D. Zip Code: 01653  Zip
Ext:
   E. Foreign Country:

3. Is this the first filing on this form by Registrant? (Y/N) N

4. Is this the last filing on this form by Registrant? (Y/N) N

5. Is Registrant a small business investment company (SBIC)? (Y/N)
N
   [If answer is''Y" (Yes), complete only items 89 through 110.]

6. ls Registrant a unit investment trust (UIT)? (Y/N) Y
   [If answer is 'Y" (Yes) complete only items 111 through 132.]

111. A.  / Depositor Namc:  First Allmerica Financial Life
Insurance Company
        B.  / File Number (If any):
        C.  / City: Worcester  Statc: MA   Zip Code: 01653  Zip
Ext.:
              / Foreign Country: Foreign Postal Code:
112. A.  / Sponsor Name:  First Allmerica Financial Life Insurance
Company
 .       B.  / File Number (If any): _
        C.  / City:  Worcester  State:  MA   Zip Code; 01653

113. A. / Trustee Name:
        B.  /  City: _ State: Zip Code: ZipExt.:
              /  Foreign Country: Foreign Postal Codc:

114. A. /  Principal Underwriter Name: Allmerica Investments, Inc.
        B. / File Number: 8-14716
        C. / City: Worcester  State: MA   Zip Code: 01653  Zip
Ext.:
            / Foreign Country:    ForeignPostalCode:

115. A. /  Independent Public Accountant Name:
PriceWaterhouseCoopers LLP
      B./ City:  Boston   State:  MA  Zip Code: 02110
                / Foreign Country: ForeignPostalCode:

116. Family of investment companies information:

      A. /  Is Registrant part of a family of investment
companies? (Y/N) Y
      B.  / Identify the family in 10 letters:  A L L M E R I C A
A
          (NOTE:In filing this form, use this identification
consistently for all investment companies in family. This
designation is for purposes of this form only.)

117. A. /  Is Registrant a separate account of an insurance
company? (Y/N) Y

        If answer is "Y" (Yes), are any of the following types of
contracts funded by the Registrant?:

        B.  / Variable annuity contracts? (Y/N)Y

        C.  / Scheduled premium variable life contracts? (Y/N) N

        D.  / Flexible premium variable life contracts? (Y/N) N

        E.  / Other types of insurance products registered under
the Securities Act of 1933 ? (Y/ N) N

118.  / Statc the number of series existing at thc end of thc
period that had securities registered under the  Securities Act of
1933................1

119.   / State the number of new series for which registration
statements under the Securities Act of  1933 became effective
during the period ..0

120.  / State the total value of the portfolio securities on the
date of deposit for the new series included  in item 119 ($000's
omitted)......0

121.  / State the number of series for which a current prospectus
was in existence at the end of  the period
 .................................. 1

122.  / State the number of existing series for which additional
units were registered under the Securities Act of 1933 during the
current period...0

123.  / State the total value of the additional units considered
in answering item 122 ($000's
omitted)............................................. $0

 124.  / State the total value of units of prior serics that were
placed in the portfolios of subsequent series during the current
period (the value of these units is to be measured on the date
they were placed in the subsequent series) ($000's
omitted)...............................................$0

125. /   State the total dollar amount of sales loads collected
(before reallowances to other brokers or dealers) by Registrant's
principal underwriter and any underwriter which is an affiliated
person    of the principal underwriter during thc current period
solely from the sale of units of all series of Registrant ($000's
omitted)...........................$0

126.  Of the amount shown in item 125, state the total dollar
amount of sales loads collected from secondary  market operations
in Regisirant's units (include the sales loads, if any, collected
on units of a prior series placed in the portfolio of a subsequent
series.) ($000's omitted).............$0

127.  List opposite the appropriate description below the number
of series whose portfolios are invested  primarily (based upon a
percentage of NAV) in each type of security shown, the aggregate
total assets at market value as of a date at or near the end of
the current period of each such group of series and the  total
income distributions made by each such group of series during the
current period (excluding distributions of realized gains, if
any):

                              Number of       Total Assets
Total Income                                   Series
($000's        Distributions
                             Investing        omitted)
($000's omitted)
A.  U.S. Treasury direct issue ..
B.   U.S Government agency ......
C.   State and municipal tax-free .
D.   Public utility debt ........
E.  Brokers or dealers debt or
    debt of brokers' or dcalers'
F.  All other corporate intermed.
     & longterm debt ............
G. All other corporate short-
     term debt ..................
H. Equity securities of brokers
    or dealers or parents of
    brokers or dealers. . . . .  .
I. Investment company equity
    securities ...............
J.  All other equity securities. ...  1             $9,505
0
K. Other securities.............
L. Total assets of all series
    of registrant .............       1             $9,505
0

128.  / Is the timely payment of principal and interest on any of
the portfolio securities held by any of Registrant's series at the
end of the current period insured or guaranteed by an entity other
than the
issuer? (Y/N) N

[If answer is "N" (No), go to item 131.]

131. Total expenses incurred by all series of Registrant during
the current reporting period($000's
omitted)..................................  $79
132.  / List the "811" (Investment Company Act of 1940)
registration number for all Series of Registrant that are being
included in this filing:
811-
811-








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