wvit_corresp2-1208.htm
December 18,
2008
VIA
EDGAR
Securities
and Exchange Commission
100 F
Street, NE
Washington,
D.C. 20549
Attn: Ms. Sally
Samuel
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Re:
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Wilshire
Variable Insurance Trust (the “Registrant”)
File Numbers
333-15881, 333-154520 and
811-07917
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Dear
Ms. Samuel:
This
letter is provided to the Securities and Exchange Commission (the “Commission”)
in connection with responses being made on behalf of the Registrant to comments
that you provided with respect to Registrant’s post-effective amendment
No. 31 to its registration statement on Form N-1A (File
No. 333-15881) filed with the Commission on December 16, 2008 and
pre-effective amendment No. 1 to the Registrant’s registration statement on
Form N-14 (File No. 333-154520) filed with the Commission on
November 26, 2008.
The
Registrant acknowledges that the adequacy and accuracy of the disclosure in such
filings is the responsibility of the Registrant. The Registrant
acknowledges that any comments or changes to disclosure in the filings reviewed
by the Commission staff, acting pursuant to delegated authority, do not
foreclose the Commission from taking any action with respect to the filings and
the Registrant represents that it will not assert staff comments as a defense in
any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.
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WILSHIRE
VARIABLE INSURANCE TRUST
By:
/s/ Lawrence E.
Davanzo
Name: Lawrence E.
Davanzo
Title:
President
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