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          Stradley Ronon Stevens & Young, LLP

          2000 K Street, N.W., Suite 700

          Washington, D.C. 20006

          Telephone  202-822-9611

          Fax  202-822-0140

          www.stradley.com

  Christopher J. Zimmerman, Esq.

  (202) 419-8402

  czimmerman@stradley.com

  April 13, 2020

  VIA EDGAR

  U.S. Securities and Exchange Commission

  Division of Investment Management

  100 F Street, N.E.

  Washington, D.C. 20549-9303

          Attention:

          Ms. Rebecca Marquigny, Esquire

          Re:

          Nationwide Variable Insurance Trust

          File Nos. 002-73024 and 811-03213

  Dear Ms. Marquigny:

  On behalf of Nationwide Variable Insurance Trust (the “Registrant”) and its series the NVIT AllianzGI International
    Growth Fund (formerly, NVIT Multi-Manager International Growth Fund), NVIT Columbia Overseas Value Fund (formerly, Templeton NVIT International Value Fund), NVIT Mellon
    Dynamic U.S. Equity Income Fund (formerly, American Century NVIT Multi Cap Value Fund), and NVIT Newton Sustainable U.S. Equity Fund (formerly, Neuberger Berman NVIT
    Socially Responsible Fund) (each, a Fund, and together, the “Funds”), below you will find the Registrant’s responses to the comments conveyed by you on April 1, 2020, with regard to Post-Effective Amendment No. 228 (the “Amendment”) to the Registrant’s
    registration statement on Form N-1A.  The Amendment was filed with the U.S. Securities and Exchange Commission (the “SEC”) on February 20, 2020, pursuant to the Investment Company Act of 1940, as amended (the “1940 Act”), and Rule 485(a)(1) under the
    Securities Act of 1933, as amended (the “Securities Act”).

  Below we have provided your comments and the Registrant’s response to each comment.  These responses will be
    incorporated into a post-effective amendment filing to be made pursuant to Rule 485(b) of the Securities Act (“485(b) filing”).  Capitalized terms not otherwise defined in this letter have the meanings assigned to the terms in the Registration
    Statement. Page numbers referenced in this letter refer to page numbers used in the 485(b) filing.

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          PROSPECTUS

          General

          1) Comment:  Please confirm that the series and classes for each Fund have been updated on the EDGAR system to reflect each respective
              Fund’s new name.

          Response:  Registrant confirms that the series and classes have been updated on the EDGAR system to reflect each Fund’s new name.

          2) Comment:  As the information provided in the “Fees and Expenses” and “Example” tables is considered material, please provide pages of
              the Prospectus showing complete, updated tables to the Staff at least five days before the filing’s effective date.

          Response:  The pages of the prospectus showing complete, updated tables are attached to this correspondence as Exhibit A.

          3) Comment:  With regard to each Fund’s 80% policy in the respective Fund’s “Principal Investment Strategies” summary, please insert the
              words “plus any borrowings for investment purposes” or confirm the Fund will not borrow in this manner. Additionally, for Funds subject to an 80% policy, pursuant to Rule 35d-1, please represent to the Staff that the corresponding policies
              are fundamental or that shareholders will receive at least 60 days’ notice in advance of the change. Finally, in each Fund’s Item 9 strategy, add a description of how this policy can be changed (e.g., shareholder vote or notice).

          Response:  Registrant respectfully declines to revise the disclosure as requested and confirms that the Funds do not intend to engage in any borrowings for
              investment purposes.  Registrant represents to the Staff that shareholders will receive at least 60 days’ notice in advance of the change in 80% policy, as it is not a fundamental policy.  In addition, Registrant respectfully declines to add
              a description of how this policy can be changed in each Fund’s Item 9 strategy discussion as such description is not required by Form N-1A, Item 9.  Registrant also notes that such description is also already included in the Statement of
              Additional Information in “Investment Restrictions.”

          NVIT AllianzGI International Growth Fund: Fund Summary

          4) Comment:  With regard to the language in the “Principal Investment Strategies” summary that states, “The Fund normally invests
              primarily in non-U.S. securities, including emerging market securities. . .”, in an appropriate place within the Registration Statement, please disclose how the Fund determines which countries qualify as emerging markets. Alternatively,
              provide a clear reference indicating where this information is already disclosed.

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          Response:  Registrant notes that further information on emerging market countries other than the information included in the Item 4 summary disclosure is located
            on page 96 of the prospectus under “Key Terms” and in the Statement of Additional Information on page 22.  Registrant respectfully declines to add cross-references in the Item 4 summary disclosure with respect to such information.

          5) Comment:  As indicated in the Names Rule Adopting Release, Rel. No. IC-24828, the Staff notes that use of the term “international”
              connotes diversification among investments in a number of different countries throughout the world. The Staff further notes that the “Principal Investment Strategies” summary states that “The Fund . . . is not limited in the percentage of its
              asset that it may invest in any one country, region or geographic area.” It is the Staff’s position that this language would permit the Fund to invest all of its assets in a single country. Accordingly, please clarify the existing disclosure
              to specify that the Fund will not invest all of its assets in a single country.

          Response:  Registrant respectfully declines to revise the Fund’s disclosure as requested.  Registrant does not believe that disclosing that the Fund does not limit
            the percentage of its assets that it may invest in any one country is the same as otherwise permitting the Fund to invest in only one country.  Registrant understands that the position of the SEC and the Staff  is that “international” connotes
            diversification among a number of different countries throughout the world and the Fund is managed consistent with such position, although Registrant also notes that the SEC and the Staff also made clear that the term “international” is not
            covered by Rule 35d-1. See Names Rule Adopting Release, Rel. No. IC-24828, f. 42.

          6) Comment:  With regard to the reference to “exposure to secular market growth drivers” in the “Principal Investment Strategies”
              summary, the meaning of the term “secular” is confusing in this context. Please either delete the word “secular” or define it the first time it appears instead of, or in addition to, the Item 9 definition.

          Response:  Registrant respectfully declines to revise its disclosure as the word “secular” is already defined in Item 9, under “Key Terms,” on page 96 of the
              prospectus.

          7) Comment:  With regard to the reference to ADRs in the “Principal Investment Strategies” summary, please add disclosure clarifying
              whether the Fund’s ADR strategy specifically anticipates investing in sponsored ADRs, unsponsored ADRs, or both.

          Response:  Registrant submits that the requested disclosure regarding depositary receipts is already a part of the discussion of “Foreign securities risk”
              disclosure under “Risks of Investing in the Fund” on page 117 of the prospectus.

          8) Comment:  Significant market events have occurred since this Post-Effective Amendment was filed, namely as a result of the COVID-19
              pandemic. Given that this is an international fund that invests specifically in markets that may be destabilized as a consequence of the new coronavirus, please consider whether the portfolio’s disclosure

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          and particularly risk disclosures, are based on how these events are affecting both debt and equity markets. If the Registrant believes that no
              additional disclosure is warranted, please supplementally explain. Likewise, apply a similar analysis throughout the filing and either amend each Fund’s disclosure accordingly or specifically explain the basis for concluding that a particular
              fund’s disclosure requires no revision.

          Response:  Registrant has updated “Market risk” in Item 9 of the prospectus as follows to address the pandemic crisis:

          Market risk is the risk that one or more markets in which a Fund invests will go down in value, including the possibility that the
              markets will go down sharply and unpredictably. In particular, market risk, including political, regulatory, market, economic and social developments, and developments that impact specific economic sectors, industries or segments of the
              market, can affect the value of a Fund’s investments. In addition, turbulence in financial markets and reduced liquidity in the markets may negatively affect many issuers, which could adversely affect a Fund. These risks may be magnified if
              certain social, political, economic and other conditions and events (such as natural disasters, epidemics and pandemics, terrorism, conflicts and social unrest) adversely interrupt the global economy; in these and other circumstances, such
              events or developments might affect companies world-wide and therefore can affect the value of a Fund’s investments.

          Additionally, Registrant has added the following disclosure to the SAI under “Additional Information on Portfolio Investments, Strategies and Investment Policies”:

          Natural Disaster/Epidemic Risk: Natural or environmental disasters, such as earthquakes, fires, floods, hurricanes,
              tsunamis and other severe weather-related phenomena generally, and widespread disease, including pandemics and epidemics, have been and can be highly disruptive to economies and markets, adversely impacting individual companies, sectors,
              industries, markets, currencies, interest and inflation rates, credit ratings, investor sentiment, and other factors affecting the value of the Fund’s investments.  Given the increasing interdependence among global economies and markets,
              conditions in one country, market, or region are increasingly likely to adversely affect markets, issuers, and/or foreign exchange rates in other countries, including the U.S.  These disruptions could prevent the Fund from executing
              advantageous investment decisions in a timely manner and negatively impact the Fund’s ability to achieve its investment objectives.  Any such event(s) could have a significant adverse impact on the value and risk profile of the Fund.

          NVIT Columbia Overseas Value Fund: Fund Summary

          9) Comment:  Please amend the Fund’s objective to read “capital appreciation and current income” rather than “capital appreciation and/or
              current income.” By

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          definition, a total return investment objective seeks both capital appreciation and current income. As a result, a fund seeking one or the other
              is not a total return fund.

          Response:  Registrant respectfully declines to revise the Fund’s investment objective.  Registrant believes that the Fund’s investment objective is accurate
              as written, as the Fund’s investment objective seeks to maximize total return through a flexible combination of capital appreciation and/or current income.

          10) Comment:  With regard to the Fund’s “Fees and Expenses” table, please include the expense reimbursement information required by Form
              N-1A, Item 3, Instruction 3(e) when Registrant submits revised fee tables via EDGAR correspondence, pursuant to Comment 2.

          Response:  Registrant confirms that it is has provided the Fund’s updated and revised Fees and Expenses table in response to Comment 2. Registrant confirms
              that the Fees and Expenses table complies with Form N-1A Item 3.

          11) Comment:  With regard to the reference to depositary receipts in the “Principal Investment Strategies” summary section, please
              indicate the types of depositary receipts that are principal to the Fund’s strategies (e.g., ADRs, GDRs, EDRs) and if such instruments may be unsponsored, so state. Additionally, add corresponding risk disclosure to Items 4 and 9.

          Response:  Registrant submits that the requested disclosure regarding depositary receipts is already a part of the discussion of “Foreign securities risk”
              disclosure under “Risks of Investing in the Fund” on page 117 of the prospectus.

          12) Comment:  With regard to the statement, “The Fund may have significant investments in one or more countries or in particular sectors”
              in the “Principal Investment Strategies” summary section, if the Fund is significantly invested in this manner at present, please disclose the applicable sectors or countries.

          Response:  Registrant respectfully declines to revise its disclosure as it believes the current disclosure is satisfactory.  Registrant notes that specific
              sector concentration may vary significantly from period to period as the investment process does not predict holdings by sector.  Additionally, Registrant believes that specific sector disclosure may not accurately reflect the principal
              investment strategy of the Fund, as the sectors may change from time to time.

          13) Comment:  With regard to the reference to derivatives in the “Principal Investment Strategies” summary section, please state how
              derivatives are valued for purposes of the Fund’s 80% test (e.g. notional or market value). Additionally, the Staff notes that the disclosure just says the Fund “may invest in derivatives such as…” Please be advised that Item 4 and 9 strategy
              discussions must specifically indicate each type of derivative instrument the Fund intends to use as principal means of achieving its investment

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          objective.  Please apply this comment comprehensively across all Funds to the extent applicable.

          Response:  Registrant believes that the use of notional value may be an appropriate measure of the economic exposure of a fund in certain circumstances.
              Notwithstanding the foregoing, Registrant historically has not used, and currently does not intend to use, the type of derivatives instruments where such treatment would be appropriate.  Accordingly, Registrant confirms that derivatives that
              provide economic exposure to assets that are consistent with its name will be valued at market value for purposes of measuring compliance with the noted 80% policy.

          Additionally, Registrant believes that the Fund’s Item 4 strategies already indicates the types of derivative instruments that the Fund intends to use as principal
              means of achieving its investment objective.

          14) Comment:  The narrative below the Highest/Lowest Quarters in the “Performance” section states, “The Fund had not commenced offering
              Class II or Class Y shares as of the date of this