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    3000 Two Logan Square

    Eighteenth and Arch Streets

    Philadelphia, PA  19103-2799

    215.981.4000

    Fax 215.981.4750

    John P. Falco

    direct dial:  215.981.4659

    falcoj@pepperlaw.com

    January 7, 2020

    Via EDGAR

            Division of Investment Management

            U.S. Securities and Exchange Commission

            100 F Street, NE

            Washington, D.C. 20549

            Attn: Christopher R. Bellacicco, Attorney

              Re:

              Third Avenue Variable Series Trust

              1933 Act File No. 333-81141

              1940 Act File No. 811-09395

    Dear Mr. Bellacicco:

    This letter addresses the oral comments of the Securities and Exchange Commission’s staff (the “Staff”) to the preliminary notice of meeting, proxy statement, and form of proxy card filed via EDGAR
      on December 6, 2019 (the “Preliminary Materials”) to be furnished to shareholders of the Third Avenue Value Portfolio (the “Portfolio”), a series of the Third Avenue Variable Series Trust (the “Trust”), in connection with a Special Meeting of
      Shareholders of the Portfolio (the “Meeting”).

    The Meeting is being called in order to ask shareholders of the Portfolio to approve a new investment sub-advisory agreement among the Trust, on behalf of the Portfolio, Third Avenue Management LLC
      (“Third Avenue” or “Adviser”), the Portfolio’s investment adviser, and Cadence Capital Management LLC (“Cadence”), the proposed sub-adviser (“Sub-Advisory Agreement”).

    We appreciate the opportunity to address the Staff’s comments regarding certain disclosures in the Preliminary Materials.  We set forth the Staff’s comments in italicized text followed by the Trust’s
      response to the Staff’s comments. In addition, revised Proxy Materials (the “Proxy Materials”) marked to show changes from the Preliminary Materials reviewed by the Staff are attached hereto as Appendix A.

    *          *          *

              1)

                Please include the following information in the “Notice of Special Meeting of Shareholders”: 1. Whether a contract owner will need any control or identification numbers to access his or her form of proxy;
                  and 2. Information on how to obtain instructions on how to attend the meeting and provide voting instructions in person.

    Response:   The Proxy Materials have been revised to reflect the Staff’s comment.

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            Wilmington

    www.pepperlaw.com

              2)

                With respect to the current investment advisory agreement between Third Avenue and the Trust (“Advisory Agreement”), please disclose the date on which it was last submitted to a vote of shareholders of the
                  Portfolio and the purpose of such submission.

    Response:   The Proxy Materials have been revised to reflect the Staff’s comment.

              3)

                The Staff notes that it is anticipated that the Portfolio will be renamed to reflect the Portfolio’s addition of Cadence’s strategy.  Please describe in more detail the Portfolio’s new investment strategies
                  and risks to be implemented in the event of shareholder approval of the Sub-Advisory Agreement.

    Response:   The Proxy Materials have been revised to reflect the Staff’s comment.

              4)

                Please confirm that the undertaking by the Adviser to waive or assign its advisory fee will be memorialized in writing and disclosure in the Proxy Materials.

    Response:   Contemporaneous with the execution of the Sub-Advisory Agreement, the Trust and Adviser will execute an amendment to the Advisory Agreement to clarify that
      Third Avenue has agreed to reduce its advisory fee in an amount equal to the sub-advisory fee paid to Cadence. Accordingly, the Proxy Materials have been revised to reflect the Staff’s comment.

              5)

                Please state the material terms of the contractual arrangement with Broadridge to assist in the solicitation of proxies.

    Response:   The Proxy Materials have been revised to reflect the Staff’s comment.

              6)

                Please place the information contained in Exhibit D of the Preliminary Materials relating to the Board of Trustees’ approval of the Sub-Advisory Agreement into the body of the proxy statement.

    Response:   The Proxy Materials have been revised to reflect the Staff’s comment.

     *          *          *

    Please direct any questions concerning this letter to the undersigned at 215.981.4659, or John M. Ford, Esq. at 215.981.4009.

            Very truly yours,

            /s/ John P. Falco

            John P. Falco

              cc:

              Joel L. Weiss, President of Third Avenue Variable Series Trust

              John M. Ford, Esq.

      THIRD AVENUE VARIABLE SERIES TRUST

            622 Third Avenue

            New York, New York 10017

            Third Avenue Value Portfolio

      [ ]January 13, 20192020

      To the owners of variable annuity contracts and variable life insurance policies entitled to give voting instructions:

      The Board of Trustees of Third Avenue Variable Series Trust (the “Trust”) has called a Special Meeting of Shareholders (the “Meeting”) of the Third Avenue Value Portfolio (the “Portfolio”), to be held at [ ] [11:00 am/pm] Eastern time on [ ]February 10, 2020, at the offices of The Bank of New York Mellon, located at 301 Bellevue Parkway, 2nd Floor, Wilmington, DE 19809. There is an
          important proposal to be considered that will impact the Portfolio which is described in greater detail in the enclosed Proxy Statement. As an owner of a variable annuity contract and/or variable life insurance policy (each, a “Policy”) entitled
          to give voting instructions with respect to the Portfolio, you are being asked to instruct your insurance company as to the manner in which the shares held by your Policy should be voted. We ask you to read the
          enclosed information carefully and to submit your voting instructions promptly.

      As set forth in more detail in the enclosed Proxy Statement, shareholders are being asked to approve a new investment sub-advisory agreement (the “New Sub-Advisory Agreement”) among the Trust, on behalf of the
          Portfolio, Third Avenue Management LLC (“Third Avenue”), the Portfolio’s current investment adviser, and Cadence Capital Management LLC (“Cadence”), the proposed sub-adviser. Under the New Sub-Advisory Agreement, Cadence will manage those assets
          of the Portfolio assigned by Third Avenue to Cadence (those assets being referred to as the “Fund Account”). If the New Sub-Advisory Agreement is approved by shareholders, Third Avenue will continue to provide investment advisory services, but
          will only provide portfolio management services to a portion of the assets of the Portfolio. Cadence, as sub-adviser, will provide investment sub-advisory services to the Portfolio’s remaining assets under the supervision of Third Avenue and the
          Board of Trustees of the Trust. The Trust will pay a sub-advisory fee to Cadence for its services to the Fund Account – however, Third Avenue has agreed to assign its right to or reduce
          its advisory fee in an amount equal to the sub-advisory fee paid to Cadence. Accordingly, the New Sub-Advisory Agreement will not result in any additional expense for Portfolio shareholders.

      Upon approval by shareholders of the New Sub-Advisory Agreement, it is anticipated that the Portfolio will be renamed the “[FFI Strategies Portfolio].” “FFI” stands for “fundamental and factor investments” strategies in order to reflect the addition of Cadence as sub-adviser to the Portfolio.

      It is important that you take a few minutes to read the enclosed material and then instruct your insurance company how to vote your shares.  You can
          submit your voting instructions by mail, telephone, or over the internet, as explained in the enclosed material. To assist you in giving your instructions, a voting instruction form is enclosed. To be effective, voting instructions must be
          received before the close of business on [ ]February 6, 2020 (the “Effective Time”). Such instructions may be revoked at any time prior to the Effective Time by written notice of revocation or another voting instruction form
          delivered to your insurance company.

      If you would like additional information concerning the proposal described above, please contact us at 800-443-1021. We thank you for your time and attention to this important matter.

                Sincerely,

                [Joel L. Weiss]

                [President]

                Third Avenue Variable
                    Series Trust

      YOUR VOTE IS IMPORTANT – PLEASE VOTE PROMPTLY.

      YOU ARE URGED TO SIGN AND MAIL THE ENCLOSED VOTING INSTRUCTION FORM IN THE ENCLOSED ENVELOPE OR VOTE BY TELEPHONE OR OVER THE INTERNET BY FOLLOWING THE ENCLOSED INSTRUCTIONS.

      THIRD AVENUE VARIABLE SERIES TRUST

            622 Third Avenue

            New York, New York 10017

            Third Avenue Value Portfolio

      NOTICE OF SPECIAL MEETING OF SHAREHOLDERS

            To Be Held on [ ]February 10, 2020

      Important Notice Regarding the Availability of Proxy Materials for the Special Meeting of Shareholders to be Held on [ ]February 10, 2020: The Notice of Special Meeting of Shareholders, Proxy Statement and Voting Instruction Form are available online at www.proxyvote.com.

      A Special Meeting of Shareholders (the “Meeting”) of Third Avenue Value Portfolio (the “Portfolio”), a series of Third Avenue Variable Series Trust (the “Trust”), will be held at the offices of The Bank of New
          York Mellon, located at 301 Bellevue Parkway, 2nd Floor, Wilmington, DE 19809, on [ ]February 10, 2020 at [ ] [11:00 am/pm] Eastern time, for the following purposes:

              1.

              To consider and act
                  upon a proposal to approve a new investment sub-advisory agreement among the Trust, on behalf of the Portfolio, Third Avenue Management LLC, the Portfolio’s investment adviser, and Cadence Capital Management LLC; and

              2.

              To consider and act
                  upon any other matters that properly come before the Meeting or any adjourned session thereof.

      The Board of Trustees of the Trust recommends that shareholders vote FOR the proposal. As an owner of a variable annuity contract and/or variable life insurance policy (each, a “Policy”) entitled to give voting
          instructions with respect to the Portfolio, you are being asked to instruct your insurance company as to the manner in which the shares held by your Policy should be voted. We ask you to read the enclosed
          information carefully and to submit your voting instructions promptly.

      This Meeting is called pursuant to the Agreement and Declaration of Trust dated June 16, 1999. Portfolio shares are offered only to separate accounts established by insurance companies to fund variable annuity contracts and
          variable life insurance policies (collectively referred to as the “Policies”). Shares held in separate accounts which are attributable to the Policies will be voted by the respective insurance company in accordance with instructions received from
          the owners of the Policies (“Policyowners”). The Board of Trustees of the Trust has fixed the close of business on [ ], 2019January 6, 2020 as the record date for the determination of the
          shareholders of the Portfolio entitled to notice of, and to vote at, the Meeting and any adjournment or postponements thereof (the “Record Date”). The Proxy Statement and accompanying materials, or a Notice of Internet Availability of Proxy
          materials, are being mailed on or about [ ], 2019January 13, 2020 to Policyowners of record as of the Record Date so that they may instruct their insurance company as to the manner in which the Portfolio shares held by their
          Policies should be voted at the Meeting. To cast a vote, simply complete the proxy card(s) enclosed in this package. Be sure to sign each card
              before mailing it in the postage-paid envelope. You may also vote your shares by touch-tone telephone or through the internet. Simply call the 1-800-690-6903 (toll-free) or visit www.proxyvote.com, enter the control number found on the
              card(s), and follow the recorded or online instructions. Directions to attend the Meeting where Policyowners may vote in person can be found online at www.proxyvote.com. Valid photo identification may be required to attend the Meeting in
              person.

      Please read the accompanying Proxy Statement for a more complete discussion of the proposal. Please complete, sign and return promptly in the enclosed postage paid return envelope the accompanying voting
          instruction form. Such instructions may be revoked by written notice of revocation or another voting instruction form delivered to your insurance company.

                By Order of the Board
                    of Trustees,

                [Vincenzo A. Scarduzio]

                Secretary

      [ ]January 13, 20192020

      YOUR VOTE IS IMPORTANT.

             PLEASE SIGN, DATE AND RETURN YOUR VOTING INSTRUCTION FORM PROMPTLY.

      THIRD AVENUE VARIABLE SERIES TRUST

            622 Third Avenue

            New York, New York 10017

            Third Avenue Value Portfolio

              (the “Portfolio”)

      PROXY STATEMENT

      A proxy statement is enclosed in connection with a Special Meeting of Shareholders (the “Meeting”) of the Third Avenue Value Portfolio (the “Portfolio”) to be held on [ ]February 10, 2020 at [     ] [11:00 am/pm] (Eastern time) at the offices of The Bank of New York Mellon (“BNY Mellon”), located at 301 Bellevue Parkway, 2nd Floor, Wilmington, DE
          19809. The Portfolio is a series of the Third Avenue Variable Series Trust (the “Trust”). The proxy is solicited on behalf of the Board of Trustees of the Trust (the “Board” or the “Trustees”). The Board has fixed the close of business on [ ], 2019January 6, 2020 as the record date (the “Record Date”) for the determination of the shareholders entitled to notice of, and to vote at, the Meeting and any adjournments or postponements thereof. Shareholders at the close of
          business on the Record Date will be entitled to one vote for each share held and fractional shares will be entitled to an equivalent fractional vote. The number of shares of beneficial interest of the Portfolio outstanding as of the Record Date
          is set forth in Exhibit A.

      Shares of the Portfolio are offered only to separate accounts established by insurance companies (“Participating Insurance Companies”) to fund variable annuity contracts and variable life insurance policies (collectively referred
          to as the “Policies”). The Participating Insurance Company’s separate accounts are the shareholders of the Portfolio. However, pursuant to applicable laws, Portfolio shares held in a separate account which are attributable to Policies will be
          voted by the relevant Participating Insurance Company in accordance with instructions received from the holders of the Policies (“Policyowners”). As a Policyowner of record as of the close of business on the Record Date, you have the right to
          instruct your Participating Insurance Company as to the manner in which shares of the Portfolio attributable to your Policy should be voted.