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        Chapman and Cutler LLP

320 South Canal Street, 27th Floor

Chicago, Illinois 60606

T 312.845.3000

F 312.701.2361

www.chapman.com

April 27, 2023

VIA EDGAR CORRESPONDENCE

Emily Rowland

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. Rowland:

This letter responds
to your comments 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 February 7, 2023 (the “Registration
Statements”). The Registration Statements relate to the First Trust Capital Strength Hedged Equity Portfolio and First Trust
Growth 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 Statements.

The Staff notes that,
unless otherwise indicated, the comments below will apply to both Funds. The Registrant’s responses below will apply to each of
the above referenced funds.

Comment
1 – General

The Staff reminds
the Registrant and its management that they are responsible for the accuracy and adequacy of the disclosures, notwithstanding any review,
comments, action or absence of action by the Staff. Where a comment is made in one location, it is applicable to all similar disclosures
appearing elsewhere in the Registration Statements. Please ensure that corresponding changes are made to all similar disclosure.

Please provide responses
to all of the Staff’s comments on EDGAR at least five days before the effective date of the Registration Statements.

Response
to Comment 1

The Registrant confirms
that corresponding changes made in response to the Staff’s comments have been made to any similar disclosure throughout the Registration
Statements and that it will provide the Staff with a response letter in the form of correspondence at least five days before effectiveness.

Comment
2 – Fee Table

Please state that
the table “describes the fees and expenses that you may pay if you buy, hold and sell shares of the Fund.”

Response
to Comment 2

The disclosure has
been revised in accordance with the Staff’s comment.

Comment
3 – Fee Table

Since there is only
one share class for each Fund, please revise the last sentence under the section entitled “Fees and Expenses of the Fund”
to state the information applies to Class I shares.

Response
to Comment 3

In accordance with
the Staff’s comment, the last sentence of the section entitled “Fees and Expenses of the Fund” has been revised as follows:

More information about
eligibility requirements for Class I shares is available from your Participating Insurance Company.

Comment
4 – Fee Table

Please add a footnote
to the fee table that “Other Expenses” is an estimate based on the expenses the Funds expect to incur for the current fiscal
year.

Response
to Comment 4

The disclosure has
been revised in accordance with the Staff’s comment.

Comment
5 – Principal Investment Strategies

Please supplementally
confirm to the Staff that each Fund is an index fund.

Response
to Comment 5

The Registrant confirms
that the First Trust Growth Strength Portfolio is an index fund. The Registrant notes that while the First Trust Capital Strength Hedged
Equity Portfolio is an actively-managed fund, the Fund uses a benchmark index (the Capital Strength IndexSM) as part of its
equity strategy.

    -2-

Comment
6 – Principal Investment Strategies

The Staff notes the
following disclosure in the section entitled “Principal Investment Strategies”:

The Index Provider
may, from time to time, exercise reasonable discretion as it deems appropriate in order to ensure Index integrity.

For the First Trust
Growth Strength Portfolio, please be more specific as to what discretion the Index Provider will use since the Index Provider must follow
a rules-based methodology.

Response
to Comment 6

The
Index Provider’s policies and procedures provide that it may make deviations from the Index methodology at its discretion so that
the Index continues to achieve its objective. The Index Provider may exercise expert judgement or discretion when the situation calls
for the interpretation of data in calculating and maintaining the Index in response to, for example, stock splits, spin-offs or other
corporate actions. The Registrant believes the disclosure, as currently presented, is consistent and aligns with the Index’s
rules-based methodology.

Comment
7 – Principal Investment Strategies

Since
the First Trust Capital Strength Hedged Equity Portfolio is an actively-managed fund,
please remove all disclosure regarding the Index Provider and Index with a summary of how the Advisor and/or Sub-Advisor selects investments
for the Fund, including how and when the Advisor and/or Sub-Advisor will sell securities.

Response
to Comment 7

In
accordance with the Staff’s comment, all disclosure relating to the Index Provider has been removed. While the Fund is actively-managed,
it uses a benchmark index (the Capital Strength IndexSM) as part of its equity strategy. The Registrant has revised
the equity strategy to better describe the role the Index plays in the Fund’s principal investment strategies. Additionally,
the following risks have been removed from the Prospectus: Index Concentration Risk, Index Provider Risk and Non-Correlation Risk.

Comment
8 – Principal Investment Strategies

For the First Trust
Growth Strength Portfolio, please describe in Item 9 more detail regarding the
filters for liquidity, return on equity, long-term debt, revenue and cash flow growth.

    -3-

Response
to Comment 8

In accordance with
the Staff’s comment, the disclosure in the section entitled “Additional Information on the Fund's Investment Objective and
Strategies” has been revised as follows:

The Index begins with
liquidity screens by filtering all securities within the NASDAQ US Benchmark Index that have less than $5 million in three-month average
daily trading volume. The Index ranks all remaining companies by float-adjusted market capitalization and removes those that fall below
the top 500 remaining securities.

All remaining securities
are filtered by three screens that seek to identify well-capitalized companies with strong market positions. These filters include excluding
companies with: (1) less than $1 billion in cash and short-term investments; (2) companies with a long-term debt to market capitalization
ratio greater than 30%; and (3) companies with a return on equity that is less than 15%.

All remaining securities
are then ranked by their three-year revenue growth percentage and three-year cash flow growth percentage. Companies are ranked in descending
order with companies that have the highest growth percentage for each screen receiving the highest relative ranking. Those rankings are
combined equally with the top 50 securities by combined rank chosen for inclusion in the Index.

Comment
9 – Principal Investment Strategies

For the First Trust
Growth Strength Portfolio, please state the expected market capitalization range for companies in the Index and specify the information
as of a recent date.

Response
to Comment 9

The
disclosure has been revised in accordance with the Staff’s comment.

Comment
10 – Principal Risks

For the First Trust
Growth Strength Portfolio, if applicable, please include a small- and/or mid-capitalization risk.

Response
to Comment 10

The
Registrant does not believe, based on the market capitalization of the Index for the First Trust Growth Strength Portfolio, a small-
and/or mid-capitalization risk is applicable to the Fund.

Comment
11 – Principal Investment Strategies

For the First Trust
Growth Strength Portfolio, please state how the Fund selects its investments (i.e., whether it is by following a replication or
sampling strategy).

    -4-

Response
to Comment 11

In accordance with
the Staff’s comment, the disclosure has been revised to add the following:

The Fund, using an
indexing investment approach, attempts to replicate, before fees and expenses, the total return performance of the Index, which includes
dividends paid by the common stocks in the Index. The Fund will generally employ a full replication strategy, meaning that it will normally
invest in all of the securities comprising the Index in proportion to their weightings in the Index.

Comment
12 – Principal Investment Strategies

The Staff notes the
disclosure states, “To the extent the Fund invests a significant portion of its assets in a given jurisdiction or investment sector,
the Fund may be exposed to the risks associated with that jurisdiction or investment sector.”

If
the Funds have significant exposure to any jurisdiction specifically, please add disclosure to the section entitled “Principal Investment
Strategies” and add appropriate risk disclosure. Additionally, please revise the above-referenced sentence to describe what the
investment sector refers to. The Staff notes the previous sentence states the Index had significant exposure to health care and information
technology companies (or industrials companies for the First Trust Capital Strength Hedged Equity Portfolio.

Response
to Comment 12

The Registrant notes
each Fund does not anticipate having significant exposure to any jurisdiction specifically. The above-referenced disclosure refers to
the Funds’ exposure to companies within the referenced GICS sectors. The Registrant believes the disclosure, as currently presented,
is accurate for investor comprehension. The Funds’ exposure to the companies listed in the disclosure represent a material investment
of each Fund. As such, the Registrant will identify these sectors and include applicable risks.

Comment
13 – Principal Risks

The Staff notes that
the principal risks appear in alphabetical order. Please order the risks to prioritize the risks that are most likely to adversely affect
the Funds’ net asset value, yield and total return.

Response
to Comment 13

The Registrant respectfully
declines to revise the disclosure as requested by the Commission. Ultimately, the Registrant has reached the same conclusion as many other
industry participants and declines to make the requested revisions as it believes the disclosure is compliant with the requirements of
Form N-1A. The Registrant continues to evaluate its approach to the ordering of risk factors in light of recent Commission guidance.

    -5-

Comment
14 – Principal Risks

The Staff notes the
“Index Provider Risk” states, “The Advisor’s mandate as described in this prospectus is to manage the Fund consistently
with the Index provided by the Index Provider.” Please explain what this sentence means (i.e., does the Advisor use a replication
or sampling strategy?).

Response
to Comment 14

The disclosure has
been revised to reflect the Fund follows a replication strategy.

Comment
15 – Principal Risks

Please update the
“Inflation Risk” to better reflect the current inflationary environment that inflation is rising.

Response
to Comment 15

In accordance with
the Staff’s comment, the “Inflation Risk” has been revised as follows:

INFLATION RISK.
Inflation risk is the risk that the value of assets or income from investments will be less in the future as inflation decreases the value
of money. The current environment of elevated inflation may cause the present value of the Fund’s assets and distributions to decline.

Comment
16 – Principal Risks

Please describe in
the section entitled “Principal Investment Strategies” that the Funds invest in large capitalization companies, if applicable.

Response
to Comment 16

The disclosure has
been revised in accordance with the Staff’s comment.

Comment
17 – Principal Risks

For the First Trust
Growth Strength Portfolio, please describe the low volatility criteria that the
Index Provider uses when selecting securities in both the “Low Volatility Risk” and in Item 9.

Response
to Comment 17

The Registrant notes
that the “Low Volatility Risk” has been removed from the Prospectus.

Comment
18 – Principal Risks

Please add “natural
disasters” to the list of events in the following sentence of the “Market Risk”:

In addition, local,
regional or global events such as war, acts of terrorism, spread of infectious diseases or other public health issues, recessions, or
other events could have a significant negative impact on the Fund and its investments.

    -6-

Response
to Comment 18

The disclosure has
been revised in accordance with the Staff’s comment.

Comment
19 – Principal Risks

The Staff notes the
“Non-Correlation Risk” states the following:

In addition, the Fund’s
portfolio holdings may not exactly replicate the securities included in the Index or the ratios between the securities included in the
Index. Additionally, in order to comply with its investment strategies and policies, the Fund portfolio may deviate from the composition
of the Index.

Please include this
concept in the section entitled “Principal Investment Strategies.” Additionally, please supplementally explain to the Staff
the circumstances in which the events in the above-referenced disclosure may occur.

Response
to Comment 19

The section entitled
“Principal Investment Strategies” has been revised to state the following:

The Fund, using an
indexing investment approach, attempts to replicate, before fees and expenses, the total return performance of the Index, which includes
dividends paid by the common stocks in the Index. The Fund will generally employ a full replication strategy, meaning that it will normally
invest in all of the securities comprising the Index in proportion to their weightings in the Index… The Index Provider reserves
the right to use qualitative judgment to include, exclude, adjust, or postpone the inclusion of a stock in the Index. Continued Index
membership of a constituent is not necessarily subject to the guidelines provided in the Index methodology. A stock may be considered
for exclusion by the Index Provider on the basis of corporate governance, accounting policies, lack of transparency and lack of representation,
despite meeting all the criteria provided in the Index methodology.

    -7-

Additionally, the following
disclosure has been added to the section entitled “Additional Information on the Fund’s Investment Objectives and Strategies.”
Please refer to the below disclosure in response to the circumstances in which full replication may not be possible.

The Fund will generally
employ a full replication strategy, meaning that it will normally invest in all of the securities comprising the Index in proportion to
their weightings in the Index. However, under various circumstances, full replication of the Index may not be possible or practicable.
In those circumstances, the Fund may purchase a sample of securities in the Index. The Fund may utilize sampling when there are practical
difficulties or substantial costs involved in replicating the Index, including to address tax and regulatory issues and respond to trading
halts and other issues related to the liquidity of Index constituents. Though it does not intend to, there may also be instances in which
First Trust may choose to overweight certain securities in the Index, purchase securities not in the Index which First Trust believes
are appropriate to substitute for certain securities in the Index, use futures or derivative instruments or utilize various combinations
of the above techniques in seeking to track the Index. The Fund may sell securities that are represented in the Index in anticipation
of their removal from the Index or purchase securities not represented in the Index in anticipation of their addition to the Index.

Comment
20 – Principal