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