SecProbe.io

CORRESP
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Magda El Guindi-Rosenbaum

+1.202.373.6091

mer@morganlewis.com

VIA EDGAR

April 22, 2025

Ashley Vroman-Lee, Esq.

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

 Re: Venerable Variable Insurance
Trust (File Nos. 811-23910 and 333-274984)

Dear Ms. Vroman-Lee:

On behalf of Venerable Variable Insurance Trust (the “Trust”),
this letter responds to comments regarding post-effective amendment no. 1 to the Trust’s registration
statement on Form N-1A, which was filed on December 20, 2024, to register thirteen new series of the Trust (the “Funds”).
For your convenience, set forth below are your comments followed by the Trust’s responses.

 1. Please submit the Funds’ completed fee tables in the
correspondence filing.

Response:
The Funds’ completed fee tables and expense examples are included in Appendix A to this letter.

 2. Please confirm whether previously waived fees and/or reimbursed
expenses are subject to recoupment. If so, please disclose the terms of recoupment and ensure the recoupment period is limited to three
years from the date of the waiver/reimbursement. Please also disclose that the recoupment would be limited to the lesser of the expense
limit at the time of wavier/reimbursement and the expense limit at the time of recoupment.

Response:
The Trust confirms that previously waived fees and/or reimbursed expenses are not subject to recoupment.

 3. With respect to the Venerable US Small Cap Fund, we note there
are sub-subadvisers. Please explain supplementally whether (i) they are SEC-registered investment advisers, (ii) they have
entered into an agreement with the Fund or the primary investment adviser, and (iii) the manager of managers exemptive application
that the Trust and primary investment adviser have filed covers the sub-subadvisers.

    Morgan, Lewis & Bockius
    llp

    1111 Pennsylvania Avenue, NW

    Washington, DC  20004
     +1.202.739.3000

    United States
     +1.202.739.3001

Response:
The Trust confirms the entities referred to as sub-subadvisers are SEC-registered investment advisers that will enter into sub-advisory
agreements with the Funds’ primary investment adviser before providing services with respect to the Funds. The Trust represents
that such entities are no longer being referred to as sub-subadvisers and, in the upcoming 485(b) filing, they will be referred to
as non-discretionary sub-advisers. The Trust further confirms that the manager of managers exemptive order issued to the Trust and primary
investment adviser on March 4, 2025 covers the sub-advisers.

 4. With respect to the Venerable US Small Cap Fund, please supplementally
explain how the Fund defines the “non-discretionary investment advice” provided by Russell Investment Management, LLC (“RIM”).
Please also provide a supplemental analysis of whether the services amount to investment advice as an investment adviser under Section 202(a)(11)
of the Investment Advisers Act of 1940 (the “Advisers Act”).

Response:
The Trust represents that “non-discretionary investment advice” was intended to refer to research services RIM would provide
to the primary investment adviser regarding potential and existing sub-advisers including due diligence services. With respect to the
Fund, RIM will not provide advice as to the value of securities or the advisability of investing in, purchasing, or selling securities,
or provide analyses or reports concerning securities; therefore, the services do not amount to investment advice as an investment adviser
under Section 202(a)(11) of the Advisers Act. The Trust further represents that, to avoid confusion, the terminology has been revised
for the 485(b) filing and will no longer be included in the Fund’s summary principal investment strategy disclosure.

 5. Please supplementally provide the appropriate broad-based securities
market index for each Fund.

Response:
Below is each Fund’s expected broad-based securities market index.

    Fund
    Benchmark

    Venerable US Small Cap Fund
    Russell 3000

    Venerable International Index Fund
    MSCI EAFE

    Venerable Mid Cap Index Fund
    Russell 3000

    Venerable Small Cap Index Fund
    Russell 3000

    Venerable Bond Index Fund
    Bloomberg US Aggregate Bond

    Venerable Intermediate Corporate Bond Index Fund
    Bloomberg US Aggregate Bond

    Venerable World Conservative Allocation Fund
    Bloomberg US Aggregate Bond

    Venerable World Moderate Allocation Fund
    MSCI World

    Venerable World Appreciation Allocation Fund
    MSCI World

    Venerable Conservative Allocation Fund
    Bloomberg US Aggregate Bond

    Venerable Conservative Appreciation Allocation Fund
    Bloomberg US Aggregate Bond

    Venerable Moderate Appreciation Allocation Fund
    MSCI World

    Venerable Appreciation Allocation Fund
    MSCI World

 6. For each Fund that is an index fund, please identify the index
the Fund will track and the index provider. Please either disclose the index in the investment objective or explain in

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the response why it is not disclosed
in the investment objective. Please also disclose the following in each Fund’s investment strategy:

 (1) Index component selection criteria (explain how index
components are included or excluded from the index);

 (2) Index weighting methodology
(explain how components of the index are weighted);

 (3) Rebalance and reconstitution process (including frequency
thereof and how and when the index changes);

 (4) Number (or range) of index components.

Response:
Below is a list of each Fund’s index and its index provider.

    Fund
    Index/Index Provider

    Venerable International Index Fund
    MSCI EAFE/MSCI

    Venerable Mid Cap Index Fund
    Russell Midcap/Russell

    Venerable Small Cap Index Fund
    Russell 2000/Russell

    Venerable Bond Index Fund
    Bloomberg US Aggregate Bond/Bloomberg

    Venerable Intermediate Corporate Bond Index Fund
    Bloomberg US Corporate 5-10 Year/Bloomberg

The Trust has determined to include in each Fund’s
investment objective a description of the index the Fund tracks rather than the name of the index because the Trust believes the description
provides more useful information for a shareholder assessing the Fund’s investment objective. The name of the index and its index
provider are disclosed in each Fund’s investment strategy. The Trust represents that the requested information about the index methodology
has been added to each Fund’s investment strategy.

 7. With respect to the Venerable International Index Fund, what
is meant by the last sentence of the first paragraph of the principal investment strategy? We note the sentence may be included for other
index funds as well.

Response:
The Trust represents that the sentence relates to the first sentence of the paragraph and is intended to indicate that the percentage
of a Fund’s net assets invested in companies in the index typically will be considerably higher than 80%. To avoid confusion, the
sentence has been moved to immediately follow the first sentence of the paragraph.

 8. For each Fund that is an index fund, please include passive
investing risk or explain why the risk is not applicable.

Response:
The Trust represents that the requested risk disclosure is included in the risk factor called “Index-Based Investing Risk.”

 9. For each Fund that has a placeholder for sector risk, please
confirm it is a principal risk and complete the sectors and sector information.

Response:
The Trust represents that appropriate and applicable sector information has been added.

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 10. We note the Venerable Bond Index Fund and Venerable Corporate
Bond Index Fund will employ a sampling approach to index investing. Please disclose in each Fund’s strategy the number (or range)
of securities in which it invests.

Response:
The Trust represents that the requested disclosure has been added.

 11. We note the Venerable Bond Index Fund and Venerable Corporate
Bond Index Fund disclose risks relating to bank loans and distressed securities. Please include those securities in the principal investment
strategy, if applicable, or delete the risk disclosure.

Response:
The Trust represents that the disclosure has been updated to delete the risk disclosures relating to bank loans and distressed securities.

 12. With respect to the Venerable World Conservative Allocation
Fund, what does “world conservative allocation” mean in the Fund’s name? Please revise the strategy disclosure to reflect
how the Fund implements a world conservative allocation strategy. We may have additional comments.

Response:
The Trust represents that “world conservative allocation” is intended to refer to the fact that (i) the Fund
will invest in equity securities of both U.S. and non-U.S. companies and (ii) that the asset allocation breakdown of the Fund (i.e.
equity vs. fixed income exposure) is intended to be 60% equity and 40% fixed income which will generally place the Fund in a conservative
risk level peer group. The Trust further represents that the current disclosure currently includes discussion of each of these.

 13. We note the investment objective for each of the Venerable
World Conservative Allocation Fund, Venerable Conservative Allocation Fund, Venerable Conservative Appreciation Allocation Fund states,
in part, that the Fund seeks a “moderate [or modest] level of total investment return.” Please disclose how the Funds define
 “moderate [or modest] level of total investment return.”

Response:
The Trust represents that the requested disclosure has been added.

 14. For each Fund that is a fund of funds, please specifically
disclose the other series of the Trust in which each Fund invests.

Response:
The Trust represents that the requested disclosure has been added.

 15. For each Fund with “World” in its name (Venerable
World Conservative Allocation Fund, Venerable World Moderate Allocation Fund, and Venerable World Appreciation Allocation Fund), please
disclose in the Item 9 strategy section the criteria that will be applied in determining that an investment is tied to a U.S. issuer
versus a non-U.S. issuer.

Response:
The Trust represents that the requested disclosure has been added.

 16. For each Fund that invests in high yield securities (Venerable
World Conservative Allocation Fund, Venerable World Moderate Allocation Fund, and Venerable World

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Appreciation Allocation Fund),
please state in the strategy that high yield securities are speculative and use the term “junk bond” like is done in the principal
risk disclosure.

Response:
The Trust represents the requested disclosure has been added.

 17. We note emerging markets are referenced in the principal risk
section for each of the Venerable World Conservative Allocation Fund, World Moderate Allocation Fund, Venerable World Appreciation Allocation
Fund, and Venerable Moderate Appreciation Allocation Fund. Please disclose in the strategy for each Fund that it invests in emerging
markets, if applicable, or delete the risk disclosure.

Response:
The Trust represents that the requested disclosure has been added.

 18. We note the strategy of each fund of funds states that the
investment adviser determines the allocation among underlying funds based on its outlook on the “business and economic cycle, relative
market valuations and market sentiment.” Please more specifically disclose how the quoted language is defined by the Funds’
investment adviser.

Response:
The Trust represents that the requested disclosure has been added.

 19. For each fund of funds, we note there are many risks in the
principal risk disclosure that do not align with the principal investment strategy disclosure. Please include detailed disclosure in
the strategy regarding the types of funds in which each Fund invests.

Response:
The Trust represents that the requested disclosure has been added.

 20. We note that each of the Venerable World Conservative Allocation
Fund, Venerable World Moderate Allocation Fund, and Venerable World Appreciation Allocation Fund discloses quantitative investing risk.
Please disclose in the strategy for each Fund that it uses models, if applicable, or delete the risk disclosure.

Response:
The Trust represents the requested disclosure has been added.

 21. With respect to the Venerable World Moderate Allocation Fund
and Venerable Moderate Appreciation Allocation Fund, please clarify what “moderate” means in the name and/or investment objective.

Response:
The term “Moderate” in each Fund’s name refers to the Fund’s approximate target strategic allocation of 60% equity
and 40% fixed income.  The Trust notes each Fund’s approximate target strategic allocation is currently included in the disclosure.
The Venerable World Moderate Allocation Fund considers “moderate long term capital appreciation” to be capital appreciation
consistent with an investment approach that balances risk and return.  The Trust represents that clarifying disclosure has been added.

 22. We note the similar names of certain fund of funds and that
certain ones have “World” in the name while others do not. Is the difference that those without “World” in their
name do not invest a minimum amount in non-U.S. securities? Please consider clarifying.

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Response:
The term “World” is included in the name of certain fund of funds where such Fund intends to invest in one or more underlying
 “world” funds (e.g., the Venerable World Equity Fund).  The Trust notes disclosure has been added regarding other series
of the Trust in which the fund of funds may invest, in response to Comment 14.  In particular, the Venerable World Conservative Allocation
Fund, Venerable World Moderate Allocation Fund, and Venerable World Appreciation Allocation Fund each identify the Venerable World Equity
Fund as an underlying fund.

 23. Please complete all missing information in Item 9 disclosure.

Response:
The Trust represents that all missing information has been completed.

 24. In the independent trustees table in the Statement of Additional
Information (the “SAI”), please disclose the principal occupation of Julian Sluyters for all of the past five years.

Response:
The Trust represents that the requested disclosure has been added.

 25. Since the Trust does not have manager of managers/disclosure
exemptive relief, please disclose in the SAI all sub-advisory fees in accordance with the requirements of Item 19(c)(3) of Form N-1A.

Response:
The Trust represents that on March 4, 2025, it received manager of managers/disclosure exemptive relief (Venerable Variable Insurance
Trust, et al., Investment Company Act Release Nos. 35467 (February 6, 2025) (Notice) and Investment Company Act Release
Nos. 35490 (March 4, 2025) (Order)).

 26. Please include each Fund’s investment restrictions in
your response since they are incomplete in the SAI.

Response:
Each Fund’s investment restrictions are included in Appendix B to this letter.

 27. Please note that a fund and its investment adviser may not
ignore the investments of affiliated and unaffiliated underlying investment companies when determining whether the fund is in compliance
with its concentration policy. Please clarify in the information about the Funds’ concentration policy that the Funds will consider
the investments of underlying investment companies when determining compliance with their own concentration policy.

Response:
The Trust represents that the requested disclosure has been added.

*            *            *            *            *

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If
you have any questions or comments, please do not hesitate to contact me at 202.373.6091.

Sincerely,

/s/ Magda
El Guindi-Rosenbaum

Magda El Guindi-Rosenbaum

 cc: Kristina Magolis, Venerable Variable
Insurance Trust

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APPENDIX A

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Venerable US Small Cap Fund

Fund Fees and Expenses

This table describes the fees and expenses that
you may pay if