wvit_corresp3-1208.htm
December 19,
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:
In
connection with the Registrant’s acceleration requests made on November 26, 2008
and December 16, 2008, this letter is provided to the Securities and Exchange
Commission (the “Commission”) with respect to 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 and
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, respectively.
The
Registrant acknowledges the following:
(1) should
the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action
with respect to the filing;
(2) the
action of the Commission or the staff, acting pursuant to delegated authority,
in declaring the filing effective, does not relieve the fund from its full
responsibility for the adequacy and accuracy of the disclosure in the filing;
and
(3) the
fund may not assert this action as 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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