January 15, 2011

Mr. Jason Fox
Staff Accountant
Securities and Exchange Commission
Division of Investment Management, Office of Insurance Products
Washington, DC 20549

This correspondence is being submitted via Edgar.

Dear Mr. Fox:
We thank you for your comments which you relayed to us via telephone
conversation on the annual filing of Wells Fargo Variable Trust for the
fiscal year ended December 31, 2011.
With respect to your comments, we submit the following responses:
****
ANNUAL REPORTS
SEC Comment:
SEC staff suggested that reference to Note 3 be added to the fair
value footnote at the end of the Portfolio of Investments.

Wells Fargo Funds Management Response:
We respectfully decline to include this reference in the footnote
reference as the securities flagged are securities that have been fair
valued by management and are correctly noted. Note 3 more
generally discusses the valuation level of all holdings of each Fund
and provides more specific information about Level 3 holdings.
Not all fair valued securities flagged with the designated footnote
are deemed Level 3 holdings.

SEC Comment:
SEC staff suggested that language for the 144A footnote at the end
of the Portfolio of Investments be expanded to state if the
securities are deemed liquid.

Wells Fargo Funds Management Response:
We respectfully decline to add additional language to the current
note. Any securities that are considered illiquid are noted in a
separate footnote denoted as (i) at the end of the Portfolio of Investments.
There is a potential that a 144A designated security
is also considered illiquid and we feel having a separate footnote
provides more flexibility in identifying the liquidity status of both
144A and any other holdings in the portfolios.

Wells Fargo Funds Management acknowledges that management is
responsible for the adequacy and accuracy of the disclosure in the filings;
staff comments or changes to disclosure in response to staff comments in
the filings reviewed by the staff do not foreclose the Commission from
taking any action with respect to the filing; and management may not
assert staff comments as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the United
States.

If you have any further questions regarding the responses contained
herein, please contact me at 617.210.3588.

Sincerely,
Jeremy DePalma
Treasurer
Wells Fargo Variable Trust
cc: Lynda Graham, Partner KPMG