FIRST ALLMERICA FINANCIAL LIFE INSURANCE COMPANY WORCESTER, MASSACHUSETTS VIA EDGAR July 24, 2001 U.S. Securities and Exchange Commission Division of Investment Management Office of Insurance Products 450 Fifth Street, NW Washington, DC 20549 Re: Withdrawal Request of Post-Effective Amendment No. 2 under The Securities Act of 1933 and Amendment No. 47 under The Investment Company Act of 1940- Form N-4 (File Nos. 333-38276 and 811-08114) Separate Account VA-K of First Allmerica Financial Life Insurance and Annuity Company Ladies and Gentlemen: Please consider this letter an application to the Securities and Exchange Commission (the "Commssion") pursuant to Rule 477 under the Securities Act of 1933, as amended (the "Securities Act"), requesting withdrawal of the Post-Effective Amendment No. 2 to the Registration Statement on Form N-4 for First Allmerica Financial Life Insurance Company (File No. 333-38276 and 811-08114), EDGAR accession number 0000912057-01-524433 filed with the commission via EDGAR on July 19, 2001. The filing includes a Prospectus for the variable annuity contracts offered by the Registrant. The purpose of the filing was to revise certain product features, primarily through the elimination of surrender charges. The filing incorrectly included examples and other disclosure that indicated the surrender charges would still apply under certain circumstances. If you have any questions on this filing, please contact the undersigned at (508) 855-4194. Sincerely, /s/ Sheila B. St. Hilaire Sheila B. St. Hilaire Assistant Vice President and Counsel