|
|
RENEE
M. HARDT
312-609-7616
rhardt@vedderprice.com
|
Re:
|
Wilshire
Variable Insurance Trust (the “Registrant”);
Post
Effective Amendment No. 35 under the Securities Act of 1933
and
No. 36 under the Investment Company Act of 1940
File Nos. 333-15881
and
811-07917
|
1)
|
Comment: With
respect to the annual returns for the Wilshire 2015 ETF Fund, Wilshire
2025 ETF Fund and Wilshire 2035 ETF Fund (the “ETF Funds”), please use a
single index for the ETF Funds’ primary benchmark index. The
ETF Funds may use a blended index as a secondary benchmark
index.
|
|
Response: The
ETF Funds have included the Wilshire 5000 Index as their primary benchmark
index.
|
2)
|
Comment: With
respect to the Income Fund, please add disclosure regarding sub-prime
mortgages and the related risks.
|
|
Response: The
following disclosure has been added to page 14 of the ETF Funds’
Prospectus and page 24 of the other Funds’
Prospectus:
|
3)
|
Comment: Under
the “Other Information” section, please revise the public reference room
telephone number to “(202)
551-8090.”
|
|
Response:
The
Registrant has revised the telephone number
accordingly.
|
4)
|
Comment: If
a Fund (or any underlying Fund) engaged in short sales to the extent that
interest on such short sales comprises 0.05%-0.10% of total net assets, it
should be included as a separate line item to the Fund’s expense table,
otherwise it may be included in “other
expenses.”
|
|
Response: During
the most recent fiscal year, none of the Funds engaged in short sales and
therefore no changes were made to any of the expense
tables.
|
5)
|
Comment: Please
confirm that the statement of additional information has disclosure
explaining proportional voting (i.e., echo
voting).
|
|
Response: Please
see the following disclosure on page 63 of the
SAI:
|