SecProbe.io

CORRESP
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David
W. Freese, Esq.

+1.215.963.5862

david.freese@morganlewis.com

VIA EDGAR

December 17, 2025

Aaron Brodsky, 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 Mr. Brodsky:

On behalf of Venerable
Variable Insurance Trust (the “Trust”), this letter responds to comments regarding post-effective amendment no. 6 to the
Trust’s registration statement on Form N-1A, which was filed on October 3, 2025, to register four new series of the Trust
(the “Funds”). For your convenience, set forth below are your comments followed by the Trust’s responses.

 1. The “Principal
                                            Investment Strategies” section of the Venerable Real Estate Fund indicates that the
                                            Fund invests in equity securities of real estate companies economically tied to the U.S.
                                            Please disclose how the phrase “economically tied” is defined.

Response:
The requested change has been made.

 2. Given
                                            the liquidity profile of the Venerable Real Estate Fund, please discuss supplementally how
                                            investing significantly in real estate investment trusts (“REITs”) is appropriate
                                            for the open-end fund structure. Please include the factors referenced in the adopting release
                                            to Rule 22e-4 under the Investment Company Act of 1940, as amended (the “1940
                                            Act”).

Response:
Consistent with the requirements of Rule 22e-4 under the 1940 Act and the Trust’s liquidity risk management program, the Adviser,
together with the Sub-Adviser, has reviewed and assessed the Fund’s potential liquidity risk and determined that the strategy is
appropriate for an open-end fund. In particular, 100% of the Fund’s portfolio securities, including the REITs in which the Fund
expects to invest (“Portfolio REITs”), are expected to be classified as highly liquid under Rule 22e-4. The factors
the Fund’s liquidity risk program administrator (the “Administrator”) considered as part of this review include, but
are not limited to:

 i. Existence
                                            of Active Market for an Asset Class or Investment; Exchange-Traded Nature of an Asset
                                            Class or Investment:

 Morgan,
                            Lewis & Bockius llp

  2222
                                            Market Street

  Philadelphia,
                                            PA 19103
    +1.215.963.5000

  United
                                            States
    +1.215.963.5001

 o The Administrator
                                            currently expects that the Fund will invest only in exchange-traded Portfolio REITs that
                                            trade in active markets.

 ii. Frequency
                                            of Trades or Quotes; Average Daily Trading Volume

 o The Administrator
                                            currently expects that the Fund’s Portfolio REITs will trade with sufficient frequency
                                            and volume to support a highly liquid classification.

 iii. Volatility
                                            of Trading Prices and Bid-Ask Spreads

 o The Administrator
                                            considers the average daily trading volume and bid-ask spreads as part of its liquidity classification
                                            model.

 iv. Standardization
                                            and Simplicity of Asset Class’s or Investment’s Structure

 o The Administrator
                                            currently expects that the Fund’s Portfolio REITs will be standardized.

 v. Restrictions
                                            on Trading; Limitations on Transfer

 o While the
                                            governing documents of most REITs include limitations on the amount of the REITs’ shares
                                            a particular investor can own, the Administrator does not expect these limitations to materially
                                            affect the liquidity of the Fund’s Portfolio REITs. The Administrator is not aware
                                            of any other restrictions on trading or limitations in transferring the Fund’s Portfolio
                                            REITs that would cause the Administrator to classify the Portfolio REITs as other than highly
                                            liquid.

 3. Please disclose
                                            what the term “focused” in the “Venerable Inflation Focused Fund”
                                            means in connection with the Fund’s strategy.

Response:
In response to this Comment, the Fund has added the following disclosure in the Principal Investment Strategies section of the prospectus:
 “In pursuing its investment objective, the Fund seeks, over the long term, to provide investment returns that exceed the level
of U.S. inflation, as measured by the Consumer Price Index for All Urban Consumers.”

 4. In
                                            connection with the Venerable Government Money Market Fund, please adopt an 80% policy for
                                            government securities and repurchase agreements collateralized by government securities,
                                            as appropriate.

Response:
The requested change has been made.

  

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If you have any
questions or comments, please do not hesitate to contact me at 215.963.5862.

Sincerely,

    /s/ David W. Freese

    David W. Freese

 cc: Kristina
                                            Magolis, Venerable Variable Insurance Trust

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