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    One
                                            International Place, 40th Floor

                                            100 Oliver Street

                                            Boston, MA 02110-2605

    +1 617 728 7100 Main

    +1 617 426 6567 Fax

    www.dechert.com

    Kaitlin McGrath

    kaitlin.mcgrath@dechert.com

    +1 617 728 7116 Direct

    +1 617 275 8395 Fax

August
7, 2023

John
F. Kernan

U.S.
Securities and Exchange Commission

Division
of Investment Management

100
F Street, N.E.

Washington,
D.C. 20549

 Re: Forethought Variable
                                            Insurance Trust (the “Registrant”) (SEC File Nos. 333-189870 and 811-22865)

Dear Mr. Kernan:

This
letter responds to comments provided on July 7, 2023 in a telephone conference with respect to the Registrant’s annual reports
for the period ended December 31, 2022 filed with the Registrant’s Form N-CSR (Accession Nos. 0001104659-23-027460 and 0001104659-23-027457)
on March 1, 2023. Summaries of the comments, and the Registrant’s responses thereto, are provided below.

Notes
to Financial Statements

 1. Comment:         Please
                                            confirm that a right of recoupment exists for fees waived and/or expenses reimbursed prior
                                            to the change of control at the Adviser on February 1, 2021, which resulted when Global Atlantic
                                            Financial Group Limited was acquired by KKR & Co. Inc. If a right of recoupment prior
                                            to this date exists, please confirm that this was approved by the Board of Trustees.

Response:         The
Registrant confirms that the Adviser retains a right of recoupment for fees waived and/or expenses reimbursed prior to the change of
control at the Adviser on February 1, 2021. Pursuant to the currently effective Operating Expenses Limitation Agreements between the
Adviser and the Registrant, on behalf of certain of the Registrant’s series, the Adviser retains the right to receive reimbursement
for any excess expense payments paid by the Adviser pursuant to each such agreement in future years on a rolling three year basis, which
currently covers a period prior to the change of control at the Adviser on February 1, 2021. The Registrant further confirms that the
Operating Expenses Limitation Agreements previously effective for any period during the last three years, including the period prior
to the change of control at the Adviser on February 1, 2021, provided the same reimbursement right to the Adviser.

The
Registrant confirms that all of the currently effective and previously effective Operating Expenses Limitation Agreements discussed above
were approved by the Board of Trustees.

 August 7, 2023

Page 2

 2. Comment:         For
                                            funds investing material percentages of their net assets in notional value terms in derivatives
                                            and which may also be subject to market and flows volatility during the fiscal year, the
                                            current indicative derivate volume disclosure included in the Notes to Financial Statements
                                            may not adequately enable users to understand the volume (long and short) of derivatives
                                            activity in their portfolios. Please consider enhancing the current disclosure to include
                                            additional information and measurement points to assist readers in understanding long and
                                            short derivatives activity in their portfolios.

Response:         The
Registrant confirms that it will review the derivatives disclosure included in the Notes to Financial Statements section in future shareholder
reports and revise to include additional information regarding the Funds’ derivatives activity. The Registrant notes that the Portfolio
of Investments section includes detailed information regarding a Fund’s derivatives exposure grouped by derivative type, and with
respect to futures contracts, separate tables relating to a Fund’s long and short futures contract positions.

*         *         *

Please call me
at (617) 728-7116 if you have any questions.

    Sincerely,

    /s/ Kaitlin McGrath

    Kaitlin McGrath

    cc
    Sarah M. Patterson

    Trent Statczar

    Elizabeth Constant

    John V. O’Hanlon

    Claire Hinshaw