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    One Financial Plaza, Hartford, CT 06103 | 800.248.7971
    | Virtus.com

April 18, 2024

Securities
and Exchange Commission

100 F Street,
NE

Washington, D.C. 20549

Attention: Anu Dubey

Re: Virtus Variable Insurance
Trust 485(a) Filing (File No. 811-04642)

Ladies and Gentlemen:

Thank you for your
telephonic comments of the staff of the U.S. Securities and Exchange Commission (the “Staff”) provided by you on April 15,
2024, pertaining to the above-referenced 485(a) filing submitted by Virtus Variable Insurance Trust (the “Trust”) on February
29, 2024. Below, we describe the changes made to the Registration Statement in response to the comments and provide any responses to or
any supplemental explanations for such comments, as requested. Unless otherwise noted, capitalized terms have the same meanings as used
in the Registration Statement.

Set forth
below is each comment and the Trust’s response thereto.

 1. Comment: Please update the Series ID for Virtus Strategic Allocation Series in EDGAR to reflect that fund’s new name.

Response:
The requested update has been made.

 2. Comment: On the cover of each fund’s prospectus, please add the ticker symbol for each class.

Response:
The funds of the Trust do not have ticker symbols, so we have made no changes in response to this comment.

 3. Comment: Please confirm to the Staff that the contractual fee waiver/expense limitation agreement applicable to each fund will
be filed as an exhibit to the registration statement.

Response:
The Trust confirms that the contractual fee waiver/expense limitation agreement applicable to each fund will be filed as an exhibit to
the registration statement.

 4. Comment: Please confirm to the Staff that the contractual fee waiver/expense limitation agreement applicable to each fund will
be effective for at least one year from the effective date of the registration statement and that as a result the date to be inserted
into the applicable footnote to each fund’s Fees and Expenses table will be at least one year from the effective date of the registration
statement.

Response:
This Trust confirms that the contractual fee waiver/expense limitation agreement applicable to each fund will be effective for at least
one year from the effective date of the registration statement and that the date to be inserted into the footnote to each fund’s
Fees and Expenses table will be April 30, 2025.

 5. Comment: Please disclose in the footnote to each fund’s Fees and Expenses table pertaining to the contractual fee waiver/expense
limitation agreement who, if anyone, is able to terminate the agreement during the listed term.

Response:
The Trust confirms that we have added to each such footnote, “Prior to April 30, 2025, only the Series’ Board may modify or
terminate the expense limitation agreement.”

  Anu Dubey, U.S. SEC

April 18, 2024

Page 2 of 8

 6. Comment: With respect to Virtus Duff & Phelps Real Estate Securities Series, please consider whether commercial
real estate market risks should be described as a separate principal risk for this fund.

Response:
After consulting with the applicable fund’s subadviser regarding current market conditions and assessing the fund’s current
exposure to commercial real estate, the Trust respectfully declines to make this change on the basis that the fund does not have significant
exposure to commercial real estate and the fund’s subadviser does not believe that the market conditions are so significantly different
from historical conditions to nevertheless make the risks associated with commercial real estate more material to the fund than other
real estate investment risks.

 7. Comment: With respect to the indexes listed in the performance table for each fund, please consider revising the parenthetical
after the index name to, “reflects no deduction for fees or expenses” or “reflects no deduction for fees, expenses or
taxes,” and please confirm that for the indexes listed that do not reference taxes in the parenthetical do reflect deduction for
taxes.

Response:
The Trust confirms that we have reviewed the calculation methodologies for the relevant indexes and adjusted the parentheticals as appropriate.
The Trust notes that certain indexes listed do reflect any dividends net of local withholding taxes, which is why some of them still do
not state that they reflect no deduction for taxes.

 8. Comment: With respect to Virtus Duff & Phelps Real Estate Securities Series, please add the three last sentences of the
third paragraph (regarding equity REITs) in “More About Principal Investment Strategies” to the principal investment strategies
section of the fund’s summary prospectus.

Response:
The Trust confirms that this change has been made.

 9. Comment: With respect to Virtus Duff & Phelps Real Estate Securities Series, please identify specific ESG factors that
the subadviser considers in its investment analysis.

Response:
The Trust confirms that the following sentence has been added to the disclosure regarding the subadviser’s consideration of ESG
factors in its investment analysis: “For example, such factors may include to what extent individual companies can receive a fiduciary
benefit and save expenses on the use of water, waste and energy, as well as their tenant/occupier satisfaction which is helpful for maintaining
occupancy, and the quality of the board, its structure, and transparency for the benefit of shareholders.”

 10. Comment: With respect to each fund that lists investment in foreign securities as a principal investment strategy, if the fund
invests in emerging markets securities as a principal strategy and does not already disclose this please add disclosure to the principal
investment strategies and risks regarding emerging markets investing.

Response:
The Trust confirms that after consultation with each applicable fund’s subadviser and assessing the funds’ current exposure
to emerging markets, the existing disclosure correctly identifies those funds investing in emerging markets as a principal strategy. Therefore,
we have made no changes in response to this comment.

 11. Comment: With respect to each fund that lists “Sector Focused Investing Risk” as a principal risk, if focusing
on a particular sector is a principal strategy please state that in the principal investment strategies.

Response:
The Trust confirms that if focusing on a particular sector is a principal strategy, the disclosure already states it, so we have made
no changes in response to this comment. The Trust notes that the risk factor, “Sector Focused Investing Risk” is intended
to be used for funds that do not intentionally focus their investments in particular sectors but either have done so in the past or have
been identified by their subadvisers as potentially doing so in the future due to the subadviser’s investment approach.

  Anu Dubey, U.S. SEC

April 18, 2024

Page 3 of 8

 12. Comment: With respect to each fund investing in ADRs, if investing in unsponsored ADRs is a principal strategy, please
disclose the specific risks of unsponsored ADRs in the risk disclosure pertaining to depositary receipts.

Response:
The Trust confirms that although investing in unsponsored ADRs is permitted, it is not a principal strategy for any of the funds other
than Virtus KAR Small-Cap Growth Series. We have added a reference to unsponsored ADRs to the third sentence of that fund’s principal
investment strategies, as follows: “Although the Series invests primarily in U.S. companies, it may invest in foreign securities
and sponsored or unsponsored depositary receipts.” We have also added disclosure to the existing Depositary Receipts risk regarding
unsponsored ADRs, as follows:

“Depositary
receipts may be issued in sponsored or un-sponsored programs. In a sponsored program, a security issuer has made arrangements to have
its securities traded in the form of depositary receipts. In an un-sponsored program, the issuer may not be directly involved in the creation
of the program. Although the U.S. regulatory requirements applicable to ADRs generally are similar for both sponsored and un-sponsored
programs, in some cases it may be easier to obtain financial and other information from an issuer that has participated in the creation
of a sponsored program. To the extent the Series invests in depositary receipts of an un-sponsored program, there may be an increased
possibility the Series would not become aware of and be able to respond to corporate actions such as stock splits or rights offerings
involving the foreign issuer of the security underlying an ADR on a timely basis. While readily exchangeable with stock in local markets,
the depositary receipts in an unsponsored program may be less liquid than those in a sponsored program.”

 13. Comment: With respect to Virtus KAR Equity Income Series, please disclose what “high-quality” means in the sentence
that reads, “The Series invests in a diversified portfolio of primarily high-quality, dividend-paying U.S. companies,” in
the principal investment strategies section of the fund’s prospectus.

Response:
The Trust confirms that we have amended the third sentence of the same paragraph as the referenced sentence to state, “The subadviser
considers companies it believes to have a durable competitive advantage, strong management and low financial risk and to be able to grow
over market cycles to be ‘high-quality’ for purposes of the fund’s investment strategy.”

 14. Comment: With respect to Virtus KAR Small-Cap Growth Series, please disclose in the fund’s principal investment strategies
what growth stocks are.

Response:
The Trust confirms that we have added the following sentence to the fund’s principal investment strategies disclosure: "The
subadviser defines ‘growth’ companies as those companies exhibiting faster growth that typically reinvest their cash flows
into their businesses to sustain growth rather than paying the cash out in the form of dividends.”

 15. Comment: With respect to Virtus KAR Small-Cap Growth Series, consideration of ESG factors is disclosed as a principal investment
strategy in the Item 9 disclosure. Please explain to the Staff why ESG Consideration is listed as an additional risk rather than a principal
risk of the fund.

  Anu Dubey, U.S. SEC

April 18, 2024

Page 4 of 8

Response:
The Virtus Funds fund complex went through an ESG-focused examination by the Staff several years ago, as a result of which the Staff advised
the fund complex to ensure that if a subadviser was considering ESG factors, even if simply integrating such factors into its investment
analysis without emphasis, it should be disclosed in the fund’s prospectus. As a result, where a subadviser considers such factors
but does not consider ESG consideration to be an independent investment strategy we added disclosure to the “More About Principal
Investment Strategies” section of the fund’s prospectus as additional information regarding how the subadviser carries out
the principal investment strategies that are listed in the summary section and to comply with the request while attempting to avoid the
opposite issue of overemphasizing the consideration of ESG factors. When such disclosure is added to the “More About Principal Investment
Strategies” rather than the summary section, we consider the risk to be an additional risk because consideration of ESG factors
is not itself principal to the fund but instead more of a background risk.

 16. Comment: With respect to Virtus KAR Small-Cap Value Series, the additional index shown in the table and the additional index
defined below the table do not match. Please reconcile.

Response:
The Trust confirms that the table has been corrected to reflect the Russell 2000® Value Index, reconciling the two references.

 17. Comment: With respect to Virtus Newfleet Multi-Sector Intermediate Bond Series, the first sentence of the fund’s principal
investment strategies disclosure states, “the Series seeks to generate high current income and total return,” but the fund
has an investment objective of long-term total return without a reference to current income. Please reconcile.

Response:
The Trust confirms that the first sentence of the fund’s principal investment strategies disclosure has been amended to instead
state, “the Series seeks to generate a competitive total return, inclusive of a high level of current income.”

 18. Comment: With respect to Virtus Newfleet Multi-Sector Intermediate Bond Series, please identify the 14 sectors in which the
fund invests and any corresponding risks.

Response:
The Trust confirms that the fund’s principal investment strategies disclosure has been amended to include the 14 sectors in the
bullet point list following the statement that the fund invests in 14 sectors, as follows:

“The Series
seeks diversification among 14 sectors as described below in order to increase return potential and reduce risk.

Under normal
circumstances, the Series invests at least 80% of its assets in fixed income securities. The Series seeks to achieve its objective by
investing in a diversified portfolio of primarily intermediate-term bonds having a dollar-weighted average duration of between three and
ten years and that are in one of the following market sectors:

§
Securities issued or guaranteed as to principal and interest by the U.S. Government, its agencies, authorities or instrumentalities.
Sectors include U.S. Treasuries and Agency Debentures;

§
Collateralized mortgage obligations (“CMOs”), real estate mortgage investment conduits (“REMICs”) and other
pass-through securities, including those issued or guaranteed as to principal and interest by the U.S. Government, its agencies, authorities
or instrumentalities. Sectors include Asset-backed Securities (ABS), Commercial Mortgage-Backed Securities (CMBS), Non-agency Residential
Mortgage-Backed Securities (RMBS), and Agency Residential Mortgage-Backed Securities (MBS);

  Anu Dubey, U.S. SEC

April 18, 2024

Page 5 of 8

§
Debt instruments issued by foreign issuers, including foreign governments and their political subdivisions and issuers located
in emerging markets. Sectors include Emerging Markets High Yield, Yankee High Quality, and Non-US Dollar;

§
Investment grade securities (primarily of U.S. issuers, secondarily of non-U.S. issuers), which are securities with credit ratings
within the four highest rating categories of a nationally recognized statistical rating organization, including short-term securities.
Sectors include Corporate High Quality, Municipals, and Taxable Municipals; and

§
High-yield debt instruments (so-called “junk bonds”), including bank loans (which are generally floating-rate). Sectors
include Corporate High Yield and Bank Loans, including both secured loans and “covenant lite” loans which have few or no financial
maintenance covenants that would require a borrower to maintain certain financial metrics.”

Further, the Trust
has added disclosure regarding “Covenant-Lite Loans Risk” and “Municipal Bonds Risk” to the fund’s principal
risks.

 19. Comment: If Virtus Newfleet Multi-Sector Intermediate Bond Series invests in covenant lite loans as a principal strategy, please
disclose the risks of those loans in the fund’s principal risks.

Response:
The Trust confirms that the following disclosure has been added to the principal risks in the summary section: “Covenant Lite Loans
Risk: The lack of financial maintenance covenants in covenant lite loans increases the risk that the fund will experience difficulty or
delays in enforcing its rights on its holdings of such loans, which may result in losses, especially during a downturn in the credit cycle.”
Further, the following disclosure has been added to the section “More About Principal Risks”:

“Covenant
Lite Loans

Because covenant
lite loans contain few or no financial maintenance covenants, they may not include terms that permit the lender of the loan to monitor
th