FIRST TRUST VARIABLE INSURANCE TRUST
                       120 EAST LIBERTY DRIVE, SUITE 400
                            WHEATON, ILLINOIS 60187


                                 April 23, 2014


Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549


    Re:    First Trust Multi Income Allocation Portfolio (the "Fund")


Ladies and Gentlemen:

      The undersigned, First Trust Variable Insurance Trust (the "Registrant")
and First Trust Portfolios L.P., the principal underwriter of the Fund, pursuant
to the provisions of Rule 461 of the General Rules and Conditions of the
Securities and Exchange Commission (the "Commission") under the Securities Act
of 1933, as amended, hereby respectfully request that the Commission grant
acceleration of the effectiveness of Pre-Effective Amendment No. 7 to the
Registrant's Registration Statement on Form N-1A (Registration No. 333-178767),
filed on April 23, 2014, so that the same may become effective at 2:00 p.m.,
Eastern Time on April 24, 2014, or as soon thereafter as practicable.

                                        Very truly yours,

                                        First Trust Variable Insurance Trust

                                        By: /s/ W. Scott Jardine
                                            -------------------------------
                                            W. Scott Jardine, Secretary


                                        First Trust Portfolios L.P.

                                        By: /s/ W. Scott Jardine
                                            -------------------------------
                                            W. Scott Jardine, Secretary