VICTORY VARIABLE INSURANCE FUNDS
Interfund Lending N-CEN Certification
Period Ending December 31, 2019

In regards to the InterFund Lending Program, I certify that the Adviser
on behalf of the Funds has implemented procedures reasonably designed
to achieve compliance with the terms and conditions of the InterFund
Lending Order which includes the following objectives: (a) that the
InterFund Loan rate will be higher than the Repo Rate, but lower than
the Bank Loan Rate; (b) compliance with the collateral requirements as
set forth in the Application; (c) Compliance with the percentage
limitations on interfund borrowing and lending; (d) Allocation of the
Interfund borrowing and lending demand in an equitable manner and in
accordance with procedures established by the Trustees; and (e) that
the InterFund Loan Rate does not exceed the interest rate on any
third-party borrowings of a borrowing Fund at the time of the InterFund
Loan.


___/s/ Colin Kinney_________ ______March 13, 2020_______________
Colin Kinney				Date
Chief Compliance Officer
Victory Funds