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    CHAPMAN AND CUTLER LLP

     111 WEST MONROE STREET

    CHICAGO, ILLINOIS 60603

April 20,
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 April 17, 2020, regarding the section entitled “Prior Related Performance
of the Advisor” contained in the correspondence filed for First Trust Variable Insurance Trust (the “Trust”)
with the staff of the Securities and Exchange Commission (the “Staff”) on April 15, 2020 (the “Correspondence”).
The Correspondence relates to the First Trust Capital Strength Portfolio (the “Fund”), a series of the Trust.
Capitalized terms used herein, but not otherwise defined, have the meanings ascribed to them in the Fund’s Registration Statement.

Comment 1 – First
Trust Capital Strength Portfolio – Prior Related Performance of the Advisor

Please disclose
that the Fund is only showing performance for First Trust Capital Strength ETF (“FTCS”) for periods during which
FTCS tracked the The Capital Strength IndexSM (the “Index”).

Response to Comment 1

Please see
the revised section of the prospectus entitled “Prior Related Performance of the Advisor” attached hereto as Exhibit
A. In response to the Staff’s comment, the following disclosure has been added:

FTCS began tracking the The Capital
Strength IndexSM on June 4, 2013. Therefore, the performance below only reflects periods during which FTCS tracked the
Index.

Comment 2 – First
Trust Capital Strength Portfolio – Prior Related Performance of the Advisor

Please disclose
that the fees and expenses of the Fund are greater than those of FTCS.

Response to Comment 2

Please see
the revised section of the prospectus entitled “Prior Related Performance of the Advisor” attached hereto as Exhibit
A. In response to the Staff’s comment, the following disclosure has been added:

Because the Fund pays higher
fees and expenses than FTCS, the returns below would be lower after the dededuction of the Fund’s fees and epenses.

********

Please call
me at (312) 845-3484 if you have any questions or issues you would like to discuss regarding these matters.

    Sincerely yours,

    Chapman and Cutler llp

    By:
    /s/ Morrison C. Warren

    Morrison C. Warren

Exhibit A

Prior Related Performance of the Advisor

The tables below illustrate the historical performance of the
First Trust Capital Strength ETF (“FTCS”), which is an index-based exchange-traded fund advised by the Advisor that
has investment objectives, policies, and strategies that are substantially similar to those of the Fund. Other than FTCS, the Advisor
manages no other funds, including private funds or accounts, that have substantially similar investment objectives, policies and
strategies to those of the Fund. As of March 31, 2020, FTCS had approximate net assets of $3,233,424,843.

The tables below also show how the performance of FTCS compares
over the time periods indicated with those of a broad measure of market performance. You cannot invest directly in an index.

FTCS began tracking the The Capital Strength IndexSM
on June 4, 2013. Therefore, the performance below only reflects periods during which FTCS tracked the Index. Because the Fund pays
higher fees and expenses than FTCS, the returns below would be lower after the dededuction of the Fund’s fees and epenses.

Of course, past performance is no indication of future results.
The tables presented here represent the performance of another fund managed by the Advisor and not the actual performance of the
Fund.

First Trust Capital Strength ETF

Average Annual Total Returns for the Periods Ended December
31, 2019

    1 Year
    3 Years
    5 Years

    Return Before Taxes
    26.72%
    15.41%
    11.15%

    Return After Taxes on Distributions
    26.03%
    14.80%
    10.51%

    Return After Taxes on Distributions and Sale of Fund Shares
    15.79%
    11.80%
    8.52%

    The
    Capital Strength IndexSM (reflects no deduction
    for fees, expenses or taxes)
    27.60%
    16.15%
    11.87%

    S&P 500® Index (reflects no deduction for fees, expenses or taxes)
    31.49%
    15.27%
    11.70%