REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Shareholders and Board of Trustees of
Victory Variable Insurance Funds

In planning and performing our audit of the financial statements of
Victory Sophus Emerging Markets VIP Series, Victory High Yield VIP
Series, Victory RS International VIP Series, Victory INCORE Investment
Quality Bond VIP Series, Victory RS Large Cap Alpha VIP Series,
Victory INCORE Low Duration Bond VIP Series, Victory 500 Index VIP
Series, and Victory RS Small Cap Growth Equity VIP Series (the
"Funds") as of and for the year ended December 31, 2020, in accordance
with the standards of the Public Company Accounting Oversight Board
(United States) (PCAOB), we considered the Funds' internal control
over financial reporting, including controls over safeguarding
securities, as a basis for designing our auditing procedures for
the purpose of expressing our opinion on the financial statements
and to comply with the requirements of Form N-CEN, but not for the
purpose of expressing an opinion on the effectiveness of the Funds'
internal control over financial reporting.  Accordingly, we express
no such opinion.

The management of the Funds is responsible for establishing and
maintaining effective internal control over financial reporting.
In fulfilling this responsibility, estimates and judgments by
management are required to assess the expected benefits and
related costs of controls. A fund's internal control over financial
reporting is a process designed to provide reasonable assurance
regarding the reliability of financial reporting and the preparation
of financial statements for external purposes in accordance with
generally accepted accounting principles (GAAP).  A fund's internal
control over financial reporting includes those policies and
procedures that (1) pertain to the maintenance of records that,
in reasonable detail, accurately and fairly reflect the transactions
and dispositions of the assets of the fund; (2) provide reasonable
assurance that transactions are recorded as necessary to permit
preparation of financial statements in accordance with GAAP, and
that receipts and expenditures of the fund are being made only in
accordance with authorizations of management and trustees of the
fund; and (3) provide reasonable assurance regarding prevention or
timely detection of unauthorized acquisition, use or disposition of
a fund's  assets that could have a material effect on the financial
statements.

Because of its inherent limitations, internal control over financial
reporting may not prevent or detect misstatements.  Also, projections
of any evaluation of effectiveness to future periods are subject to
the risk that controls may become inadequate because of changes in
conditions, or that the degree of compliance with the policies or
procedures may deteriorate.

A deficiency in internal control over financial reporting exists when
the design or operation of a control does not allow management or
employees, in the normal course of performing their assigned
functions, to prevent or detect misstatements on a timely basis.
A material weakness is a deficiency, or combination of deficiencies,
in internal control over financial reporting, such that there is a
reasonable possibility that a material misstatement of the Funds'
annual or interim financial statements will not be prevented or
detected on a timely basis.

Our consideration of the Funds' internal control over financial
reporting was for the limited purpose described in the first
paragraph and would not necessarily disclose all deficiencies
in internal control that might be material weaknesses under
standards established by the PCAOB.  However, we noted no
deficiencies in the Funds' internal control over financial
reporting and its operation, including controls over safeguarding
securities, that we consider to be a material weakness as defined
above as of December 31, 2020.

This report is intended solely for the information and use of
management and the Board of Trustees of the Funds and the
Securities and Exchange Commission and is not intended to be
and should not be used by anyone other than these specified parties.

COHEN & COMPANY, LTD.
Cleveland, Ohio
February 16, 2021