March 15, 2000



Allmerica Financial Life Insurance and Annuity Company
440 Lincoln Street
Worcester, MA 01653

RE:      SEPARATE ACCOUNT FUVUL OF ALLMERICA FINANCIAL
         LIFE INSURANCE AND ANNUITY COMPANY

Gentlemen:

This opinion is furnished in connection with the filing by Allmerica Financial
Life Insurance and Annuity Company of this Initial Registration Statement on
Form S-6 of its flexible premium variable life insurance policies ("Policies")
allocated to the Separate Account FUVUL under the Securities Act of 1933. The
Prospectus included in this 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 30 or a person
age 45 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/ William H. Mawdsley

                                          William H. Mawdsley, FSA, MAAA
                                          Vice President and Actuary