GRESHAM VARIABLE INSURANCE SERIES TRUST
N-8A, 1996-12-18
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                      SECURITIES AND EXCHANGE COMMISSION
                            Washington, DC  20549

                                  FORM N-8A

                         NOTIFICATION OF REGISTRATION
                    FILED PURSUANT TO SECTION 8(a) OF THE
                        INVESTMENT COMPANY ACT OF 1940

The undersigned investment company hereby notifies the Securities and Exchange
Commission  that  it registers under and pursuant to the provisions of Section
8(a)  of  the  Investment  Company  Act  of  1940  and in connection with such
notification  of  registration  submits  the  following  information:

Name:  GRESHAM  VARIABLE  INSURANCE  SERIES  TRUST

Address  of  Principal  Business  Office:

     565  Fifth  Avenue,  Third  Floor
     New  York,  NY  10017

Telephone  Number:  (212)  984-1420

Name  and  Address  of  Agent  for  Service  of  Process:

     Jonathan  Spencer
     565  Fifth  Avenue,  Third  Floor
     New  York,  NY  10017


Check  Appropriate  Box:

Registrant is filing a Registration pursuant to Section 8(b) of the Investment
Company  Act of 1940 concurrently with the filing of Form N-8A: [X] Yes
[  ] No

                                  SIGNATURES

Pursuant  to  the  requirements  of  the  Investment  Company Act of 1940, the
registrant  has  caused this notification of registration to be duly signed on
its  behalf  in  the City of New York and State of New York on the 17th day of
December,  1996.

                                SIGNATURE: GRESHAM  VARIABLE
                                           INSURANCE  SERIES  TRUST


                                       By: /s/ DR. HENRY G. JARECKI
                                           ___________________________________
                                               Dr. Henry G. Jarecki

ATTEST: /s/ JONATHAN SPENCER
        ________________________
                 Name

        ________________________
                 Title


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