December 1, 2000



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


RE:     GROUP VEL ACCOUNT OF FIRST ALLMERICA FINANCIAL LIFE INSURANCE COMPANY
        FILE NO. 811-7663

Gentlemen:

This opinion is furnished in connection with the filing by First Allmerica
Financial Life Insurance Company of the Initial Registration Statement on Form
S-6 of its group premium variable life insurance policies ("Policies") allocated
to the Group VEL Account under the Securities Act of 1933. The Prospectuses
included in this Initial Registration Statement describe the Policies. I am
familiar with and have provided actuarial advice concerning the preparation of
the Initial Registration Statement, including exhibits.

In my professional opinion, the illustrations of death benefits and cash values
included in Appendix C of the Prospectuses, 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 Initial
Registration Statement.

                                             Sincerely,

                                             /s/ Paul T. Engeriser

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