CORRESP 1 filename1.txt FIRST TRUST VARIABLE INSURANCE TRUST 120 EAST LIBERTY DRIVE, SUITE 400 WHEATON, ILLINOIS 60187 April 23, 2014 Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Re: First Trust Multi Income Allocation Portfolio (the "Fund") Ladies and Gentlemen: The undersigned, First Trust Variable Insurance Trust (the "Registrant") and First Trust Portfolios L.P., the principal underwriter of the Fund, pursuant to the provisions of Rule 461 of the General Rules and Conditions of the Securities and Exchange Commission (the "Commission") under the Securities Act of 1933, as amended, hereby respectfully request that the Commission grant acceleration of the effectiveness of Pre-Effective Amendment No. 7 to the Registrant's Registration Statement on Form N-1A (Registration No. 333-178767), filed on April 23, 2014, so that the same may become effective at 2:00 p.m., Eastern Time on April 24, 2014, or as soon thereafter as practicable. Very truly yours, First Trust Variable Insurance Trust By: /s/ W. Scott Jardine ------------------------------- W. Scott Jardine, Secretary First Trust Portfolios L.P. By: /s/ W. Scott Jardine ------------------------------- W. Scott Jardine, Secretary