December 1, 2006 Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 Attention: Alison White, Esq. Re: BB&T Variable Insurance Funds (File Nos. 333-121205 and 811-21682): Registration Statement on Form N-14_(Registration No. 333-138725) ---------------------------------------------------------------- Ladies and Gentlemen: Pursuant to Rule 461 under the Securities Act of 1933, as amended, the undersigned hereby requests that the effective date for its Registration Statement on Form N-14 referenced above be accelerated so that it will become effective at 5:00 p.m. Washington, D.C. time on December 15, 2006 or as soon as practicable thereafter. Very truly yours, BB&T VARIABLE INSURANCE FUNDS By: /s/ James T. Gillespie ------------------------- Name: James T. Gillespie Title: Vice President