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                                                              March 14, 2002



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


RE:  SEPARATE ACCOUNT SPVL OF FIRST ALLMERICA FINANCIAL
      LIFE INSURANCE COMPANY
      INITIAL REGISTRATION STATEMENT (FILE NO. 811-10133)

Gentlemen:

In my capacity as Assistant Vice President and Counsel of First Allmerica
Financial Life Insurance Company (the "Company"), I have participated in the
preparation of this Initial Registration Statement for the Separate Account SPVL
on Form S-6 under the Securities Act of 1933 with respect to the Company's
modified single premium variable life insurance policies.

I am of the following opinion:

1.      The Separate Account SPVL is a Separate Account of the Company validly
        existing pursuant to the Delaware Insurance Code and the regulations
        issued thereunder.

2.      The assets held in the Separate Account SPVL equal to the reserves and
        other Policy liabilities of the Policies which are supported by the
        Separate Account SPVL are not chargeable with liabilities arising out of
        any other business the Company may conduct.

3.      The individual modified single premium variable life insurance policies,
        when issued in accordance with the Prospectus contained in this Initial
        Registration Statement and upon compliance with applicable local law,
        will be legal and binding obligations of the Company in accordance with
        their terms and when sold will be legally issued, fully paid and
        non-assessable.

In arriving at the foregoing opinion, I have made such examination of law and
examined such records and other documents as in my judgment are necessary or
appropriate.

I hereby consent to the filing of this opinion as an exhibit to this Initial
Registration Statement of the Separate Account SPVL on Form S-6 filed under the
Securities Act of 1933.

                                           Very truly yours,

                                           /s/ Sheila B. St. Hilaire

                                           Sheila B. St. Hilaire
                                           Assistant Vice President and Counsel