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    CHAPMAN AND CUTLER LLP

     111 WEST MONROE STREET

    CHICAGO, ILLINOIS 60603

April 9,
2020

VIA EDGAR CORRESPONDENCE

Jennifer Hardy

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    First
Trust Variable Insurance Trust (the “Trust”)

    File Nos. 333-178767; 811-22652

Dear Ms. Hardy:

This letter
responds to your comments, provided by telephone on March 17, 2020, regarding the registration statements filed on Form N-1A
for First Trust Variable Insurance Trust (the “Trust”) with the staff of the Securities and Exchange Commission
(the “Staff”) on January 31, 2020 (the “Registration Statements”). The Registration Statements
relate to the First Trust Capital Strength Portfolio and First Trust International Developed Capital Strength Portfolio (each a
“Fund” and collectively, the “Funds”), each a series of the Trust. Capitalized terms used
herein, but not otherwise defined, have the meanings ascribed to them in the Registration Statement.

Unless otherwise
noted, all comments and responses apply to each of the Funds.

Comment 1 – Both
Funds – General

Please note
that where a comment is made in one section of the Registration Statements, such comment is applicable to all similar disclosures
appearing elsewhere in the Registration Statements.

Response to Comment 1

The Funds confirm
that revisions made in accordance with the Staff’s comments have been applied to similar disclosure throughout the Registration
Statements.

Comment 2 – Both
Funds – General

Please provide
all missing and bracketed information along with your response to the Staff’s comments on EDGAR no later than five business
days prior to the effective date of the Registration Statements to give the Staff adequate time to review the Trust’s responses.
Please make sure the response includes the disclosure changes that the Funds intend to make in response to staff comments. This
can be done either by including the pages of the Registration Statements with the revised disclosure in the correspondence filing
or by clearly indicating the revised disclosure in the response letter. Also, in light of the Staff’s questions regarding
whether the Funds are index funds, and the prior performance presentation, the Staff would expect that these filings would not
go effective until Staff comments are resolved and the Funds may need to file a BXT.

Response to Comment 2

Pursuant to
the Staff’s request, all missing and bracketed information has been provided and any changes in accordance with the Staff’s
comments have been made to the Registration Statements as described herein, which has been filed at least five days prior to effectiveness
of the Registration Statements.

Comment 3 – Both
Funds – General

Please include
hyperlinks for all exhibits incorporated by reference in the exhibit list per the FAST Act Modernization and Simplification of
Regulation S-K (the “FAST Act”).

Response to Comment 3

Pursuant to
the Staff’s request, the Funds confirm that all exhibits in the exhibit list will include a hyperlink per the FAST Act.

Comment 4 – Both
Funds – General

Please confirm
whether the Funds intend to rely on Rule 30e-3 of the Investment Company Act of 1940, as amended (the “1940 Act”).

Response to Comment 4

The Funds do
not currently intend to rely on Rule 30e-3 of the 1940 Act.

Comment
5 – Both Funds – Investment Objective

The Staff notes
that it appears from the disclosure, that the Funds may be index funds because they are replicating an index. Please revise the
Funds’ objectives to state that their objectives are to track the performance of an index or explain why the Funds are not
index funds.

Response to Comment 5

While each
Fund does intend to track the performance of an index, their investment objective is to seek to provide capital appreciation. Each
Fund has adopted a policy to invest at least 80% of its assets (including investment borrowings) in its respective index.

Comment 6 – Both
Funds – Fees and Expenses of the Fund

Please indicate
that the Funds’ “Other Expenses” are estimated for the first fiscal year in a footnote.

Response to Comment 6

The requested
footnote has been added to the Annual Fund Operating Expenses table on page 3 of each Fund’s prospectus.

Comment 7 – Both
Funds – Fees and Expenses of the Fund

The Staff notes
that the agreement described in footnote (1) to the Annual Fund Operating Expenses table must be for a term of one year from the
effective date of the Registration Statements and asks the Funds to please disclose this in the table and in the footnotes.

Response to Comment 7

The Funds confirm
that an expiration date that is at least one year from the effective date of the Registration Statements has been added to
footnote (1) on page 3 of each Fund’s prospectus.

Comment 8 – Both
Funds – Fees and Expenses of the Fund

In the second
sentence of footnote (1) to the Annual Fund Operating Expenses table, please change “incurred” to “initially
waived or reimbursed.”

Response to Comment 8

Footnote (1)
on page 3 of each Fund’s prospectus has been revised in accordance with this comment.

Comment 9 – Both
Funds – Fees and Expenses of the Fund

In the second
sentence of footnote (1) to the Annual Fund Operating Expenses table, please replace “for the most recent fiscal year for
which such expense limitation was in place” with “as of the time of reimbursement.” Please consider revising
this disclosure to combine “(i)” and “(ii).”

Response to Comment 9

The disclosure
as provided is consistent with the Fee Waiver and Expense Reimbursement Agreements between the between the Trust, on behalf of
the Funds, and the Funds’ investment advisor. The Funds believe that the Agreements and the current disclosure are also consistent
with Staff guidance regarding such arrangements.

Comment 10 – Both
Funds – Fees and Expenses of the Fund

In the second
sentence of footnote (1) to the Annual Fund Operating Expenses table, please add “(after the amount of reimbursement is taken
into account) the lesser of” immediately before “(i).”

Response to Comment 10

Footnote (1)
on page has 3 of each Fund’s prospectus has been revised in accordance with this comment.

Comment 11 – Both
Funds – Example

At the end
of the paragraph under the section entitled “Example,” please add “whether you redeem or hold all of your shares.”

Response to Comment 11

Page 3 of each
Fund’s prospectus has been revised in accordance with this comment.

Comment 12 – Both
Funds – Example

Because these
are new series, please delete the five and ten year examples.

Response to Comment 12

Page 3 of each
Fund’s prospectus has been revised in accordance with this comment.

Comment 13 – Both
Funds – Principal Investment Strategies

Please disclose
the expected market capitalization ranges for the Funds’ investments and the market capitalization ranges of the companies
in the benchmark indices as of a recent date. Please also add the relevant market capitalization risks.

Response to Comment 13

The following
disclosure has been added to page 4 of each Fund’s prospectus:

The Fund may invest in securities
of any market capitalization.

Comment 14 – Both
Funds – Principal Investment Strategies

The Staff notes
that if the Funds are not index funds, they cannot rely on the following disclosure: “The Fund will be concentrated in an
industry or a group of industries to the extent that the Benchmark is so concentrated.” The Staff also asks the Funds to
reconcile this disclosure with the fundamental policy in the Statement of Additional Information that states that the Funds are
not concentrated in any one industry or group of industries.

Response to Comment 14

The Funds intend
to operate as index funds. The references to “benchmark” have been removed in their entirety from the Registration
Statements. The fundamental policy in the Statements of Additional Information that states that the Funds are not concentrated
in any one industry or group of industries will be revised to include “except to the extent that the Fund's Index invests
more than 25% of its assets in securities of issuers in any one single industry or group of industries.”

Comment 15 – First
Trust Capital Strength Portfolio – Principal Investment Strategies

The Staff notes
that the investments in the Fund appear to be stocks of U.S. companies or REITs and asks the Fund to clarify why “jurisdiction”
is included in the last sentence of the fourth paragraph in the section entitled “Principal Investment Strategies”
and to please revise accordingly. Please also revise that sentence to state the specific sectors that the Fund invests a significant
portion of its assets in and include the applicable risks.

Response to Comment 15

Pursuant to
the Staff’s request, “jurisdiction” has been removed from page 4 of each Fund’s prospectus. As of April
2, 2020, the Fund did not invest a significant portion of its assets in any specific sector(s). Pages 4 and 5 of the Fund’s
prospectus have been revised accordingly.

Comment 16 – First
Trust International Developed Capital Strength Portfolio – Principal Investment Strategies

Please revise
the last sentence of the fourth paragraph in the section entitled “Principal Investment Strategies” to state the specific
jurisdictions and/or sectors that the Fund invests a significant portion of its assets in and include the applicable risks.

Response to Comment 16

Pages
4 and 5 of the Fund’s prospectus have been revised in accordance with this comment.

Comment 17 – Both
Funds – Principal Investment Strategies

Please move
the bolded trademark disclosure included in the section entitled “Principal Investment Strategies” as this not permitted
nor required by Item 4 of Form N-1A.

Response to Comment 17

Page 4 of each
Fund’s prospectus has been revised in accordance with this comment.

Comment 18 – Both
Funds – Principal Risks

Please delete
the following sentence: “The order of the below risk factors does not indicate the significance of any particular risk factor.”
Additionally, the Staff notes that the Principal Risks are listed in alphabetical order and asks the Funds to please revise the
order in which risks are disclosed to prioritize those that are most likely to adversely affect the Funds’ net asset value,
yield and total return in accordance with the Staff’s guidance in ADI 2019-08 – Improving Principal Risks Disclosure.
The Staff notes that “Cyber Security Risk” cannot be the most significant risk for these Funds.

Response to Comment 18

The Funds respectfully
decline to revise the disclosure as requested by the Staff. Ultimately, the Funds have reached the same conclusion as many other
industry participants and decline to make the requested revisions as they believe the disclosure is compliant with the requirements
of Form N-1A. The Funds continue to evaluate their approach to the ordering of risk factors in light of recent Staff guidance.

Comment 19 – Both
Funds – Principal Risks

If these are
not index funds, please add “Management Risk.”

Response to Comment 19

The Funds intend
to operate as index funds. Accordingly, Index Provider Risk, Non-Correlation Risk and Passive Investment Risk have been added to
pages 4-5 of each Fund’s prospectus.

Comment 20 – Both
Funds – Principal Risks

Please expand
upon the risks associated with a low volatility strategy in the “Low Volatility Risk” in the Item 4 disclosure. Please
also revise the “Low Volatility Risk” in the Item 9 disclosure to add more detail, including: (i) that it may not protect
against market decline, (ii) that it may limit the Funds’ participation in market gains, particularly during periods when
market values are increasing, but market volatility is high, (iii) that it may increase portfolio transaction costs, which could
result in losses or reduce gains, and (iv) that it may not be successful.

Response to Comment 20

Pages 5 and
10 of each Fund’s prospectus have been revised in accordance with this comment.

Comment 21 – First
Trust Capital Strength Portfolio – Principal Risks

The Staff notes
that the investments in the Fund appear to be stocks of U.S. companies or REITs and asks the Fund to please remove the references
to “country,” “state” and “region” in the “Significant Exposure Risk.” Please also
identify any industry or sector, other than financials and industrials which have already been included, in which the Fund invests
a large percentage of its assets and provide applicable risk disclosure.

Response to Comment 21

Page 6 of each
Fund’s prospectus has been revised in accordance with this comment. See Response to Comment 15.

Comment 22 – Both
Funds – Performance

Please advise
supplementally what broad-based securities index each Fund intends to use.

Response to Comment 22

The Funds intend
to use the S&P 500 Index and MSCI World ex USA Index, respectively.

Comment 23 – Both
Funds – Management

Please state
the month and the year that each Investment Committee member has served as a part of the portfolio management team.

Response to Comment 23

Page 6 of each
Fund’s prospectus has been revised in accordance with this comment.

Comment 24 – Both
Funds – Additional Information on the Fund’s Investment Objective and Strategies

Please remove
the brackets around “fundamental” in the first paragraph in the section entitled “Additional Information on the
Fund’s Investment Objective and Strategies.”

Response to Comment 24

Page 8 of each
Fund’s prospectus has been revised in accordance with this comment.

Comment 25 – Both
Funds – Additional Information on the Fund’s Investment Objective and Strategies

Please clarify
which policies the following disclosure is referring to: “Each of the policies described herein are non-fundamental policies
that may be changed by the Board of Trustees of the Trust (the “Board”) without shareholder approval.”

Response to Comment 25

This disclosure
refers to any policy described in the prospectus that is not identified as being fundamental.

Comment 26 – Both
Funds – Additional Information on the Fund’s Investment Objective and Strategies

The Staff notes
that Form N-1A provides that the principal investment strategies required by Item 4 in the summary should be based on the information
given in response to Item 9 and should be a summary of that information. The Staff states that if the Funds’ position is
that they disclose everything about their principal investment strategies in the summary, then the Funds have not provided a summary
or followed the layered disclosure regime adopted by the Commission in the June 2014 guidance regarding mutual fund enhanced disclosure.
Please provide more fulsome disclosure on how the Funds’ advisors decide which securities to buy and sell, and if these are
index funds, please revise the disclosure accordingly.

Response to Comment 26

The Funds believe
that the disclosure, as currently separated between Items 4 and 9, is compliant with the requirements of Form N-1A and is presented
in a manner conducive to investor comprehension. The Fund notes that part C.3.(a) of Form N-1A states that “information that
is included in response to Items 2 through 8 need not be repeated elsewhere in the prospectus.”

The Registration
Statements have otherwise been revised generally to reflect that the Funds are index funds.

Comment 27 – Both
Funds – Additional Information on the Fund’s Investment Objective and Strategies

The Staff notes
that all principal risks must be disclosed pursuant to Item 9(c) of Form N-1A and asks the Funds to please delete the clause “in
addition to the Principal Risks set forth above in this prospectus” from the first paragraph in the section entitled “Risks
of Investing in the Fund.”

Response to Comment 27

Page 8 of each
Fund’s prospectus has been revised in accordance with this comment.

Comment 28 – Both
Funds – Additional Information on the Fund’s Investment Objective and Strategies

The Staff no