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 RS
Large Cap Alpha 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, 2022, 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, 2022.
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.

/s/ COHEN & COMPANY, LTD.
Cleveland, Ohio
February 16, 2023