FORM N SAR

SEMI-ANNUAL REPORT

FOR REGISTERED INVESTMENT COMPANIES

Report for six month period ending: // (a)

or fiscal year ending: 12/31/04

ls this a transition report? (Y/N) N

Is this an amendment to a previous filing? (Y/N) Y

Those items or sub-items with a box " / " after the item number should be

completed only if the answer has changed from the previous filing on this

form.

1A. Registrant Name: First Allmerica Financial Life Insurance Company Group

VEL

B. File Number: 8l1-7663

C. Telephone Number: 508-855-6982

2.A. Street: 440 Lincoln Street

B. City: Worcester C. State: MA D. Zip Code: 01653 Zip Ext:

E. Foreign Country:

3. Is this the first filing on this form by Registrant? (Y/N) N

4. Is this the last filing on this form by Registrant? (Y/N) N

5. Is Registrant a small business investment company (SBIC)? (Y/N) N

[If answer is''Y" (Yes), complete only items 89 through 110.]

6. ls Registrant a unit investment trust (UIT)? (Y/N) Y

[If answer is 'Y" (Yes) complete only items 111 through 132.]

111. A. / Depositor Name: First Allmerica Financial Life Insurance Company

B. / File Number (If any):

C. / City: Worcester State: MA Zip Code: 01653 Zip Ext.:

/ Foreign Country: Foreign Postal Code:

112. A. / Sponsor Name: First Allmerica Financial Life Insurance Company

. B. / File Number (If any): _

C. / City: Worcester State: MA Zip Code; 01653

113. A. / Trustee Name:

B. / City: _ State: Zip Code: ZipExt.:

/ Foreign Country: Foreign Postal Codc:

114. A. / Principal Underwriter Name: Allmerica Investments, Inc.

B. / File Number: 8-14716

C. / City: Worcester State: MA Zip Code: 01653 Zip Ext.:

/ Foreign Country: ForeignPostalCode:

115. A. / Independent Public Accountant Name: PriceWaterhouseCoopers LLP

B./ City: Boston State: MA Zip Code: 02110

/ Foreign Country: ForeignPostalCode:

116. Family of investment companies information:

A. / Is Registrant part of a family of investment companies? (Y/N) Y

B. / Identify the family in 10 letters: A L L M E R I C A A

(NOTE:In filing this form, use this identification consistently for

all investment companies in family. This designation is for purposes of this

form only.)

117. A. / Is Registrant a separate account of an insurance company? (Y/N) Y

If answer is "Y" (Yes), are any of the following types of contracts

funded by the Registrant?:

B. / Variable annuity contracts? (Y/N)N

C. / Scheduled premium variable life contracts? (Y/N) N

D. / Flexible premium variable life contracts? (Y/N) Y

E. / Other types of insurance products registered under the

Securities Act of 1933 ? (Y/ N) N

118. / State the number of series existing at thc end of thc period that had

securities registered under the Securities Act of 1933................2

119. / State the number of new series for which registration statements

under the Securities Act of 1933 became effective during the period ..0

120. / State the total value of the portfolio securities on the date of

deposit for the new series included in item 119 ($000's omitted)......0

121. / State the number of series for which a current prospectus was in

existence at the end of the period .................................. 1

122. / State the number of existing series for which additional units were

registered under the Securities Act of 1933 during the current period...0

123. / State the total value of the additional units considered in answering

item 122 ($000's omitted)............................................. $0

124. / State the total value of units of prior series that were placed in

the portfolios of subsequent series during the current period (the value of

these units is to be measured on the date they were placed in the subsequent

series) ($000's omitted)...............................................$0

125. / State the total dollar amount of sales loads collected (before

reallowances to other brokers or dealers) by Registrant's principal

underwriter and any underwriter which is an affiliated person of the

principal underwriter during thc current period solely from the sale of units

of all series of Registrant ($000's omitted)...........................$0

126. Of the amount shown in item 125, state the total dollar amount of sales

loads collected from secondary market operations in Regisirant's units

(include the sales loads, if any, collected on units of a prior series placed

in the portfolio of a subsequent series.) ($000's omitted).............$0

127. List opposite the appropriate description below the number of series

whose portfolios are invested primarily (based upon a percentage of NAV) in

each type of security shown, the aggregate total assets at market value as of

a date at or near the end of the current period of each such group of series

and the total income distributions made by each such group of series during

the current period (excluding distributions of realized gains, if any):

Number of Total Assets Total Income

Series ($000's Distributions

Investing omitted) ($000's omitted)

A. U.S. Treasury direct issue ..

B. U.S Government agency ......

C. State and municipal tax-free .

D. Public utility debt ........

E. Brokers or dealers debt or

debt of brokers' or dealers'

F. All other corporate midterm

& longterm debt ............

G. All other corporate short-

term debt ..................

H. Equity securities of brokers

or dealers or parents of

brokers or dealers. . . . . .

I. Investment company equity

securities ...............

J. All other equity securities. ... 2 $2,572

K. Other securities.............

L. Total assets of all series

of registrant ............. 2 $2,572

128. / Is the timely payment of principal and interest on any of the

portfolio securities held by any of Registrant's series at the end of the

current period insured or guaranteed by an entity other than the issuer?

(Y/N) N

[If answer is "N" (No), go to item 131.]

131. Total expenses incurred by all series of Registrant during the current

reporting period($000's omitted).................................. $15

132. / List the "811" (Investment Company Act of 1940) registration number

for all Series of Registrant that are being included in this filing:

811-

811-