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                                                              June 21, 2002

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

RE: SEPARATE ACCOUNT SPVL OF FIRST ALLMERICA FINANCIAL LIFE INSURANCE COMPANY
    PRE-EFFECTIVE AMENDMENT NO. 1
    FILE NO. 333-84310/811-10133

Gentlemen:

This opinion is furnished in connection with the filing by First Allmerica
Financial Life Insurance Company of the Pre-Effective Amendment to the
Registration Statement on Form S-6 of its modified single premium variable life
insurance contract ("Contract") allocated to the Separate Account SPVL under the
Securities Act of 1933. The Prospectus included in this Pre-Effective Amendment
to the Registration Statement describes the Contract. I am familiar with and
have provided actuarial advice concerning the preparation of this Pre-Effective
Amendment 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
Contract. The rate structure of the Contract 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 Contract
for a person age 55 or a person age 65 than to prospective purchasers of
Contracts for people at other ages or underwriting classes.

I am also of the opinion that the aggregate fees and charges under the Contract
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 to the Registration Statement.

                                       Sincerely,

                                       /s/ Paul T. Engeriser

                                       Paul T. Engeriser, F.S.A., M.A.A.A.
                                       Vice President and Actuary