MENTOR VARIABLE
INVESTMENT PORTFOLIOS
901 East Byrd Street
Richmond, Virginia 23211
April 13, 1999
VIA EDGAR
U.S. Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: Post-effective Amendment No. 1 for Mentor Variable Investment
Portfolios (File Nos. 333-23939, 811-08153)
Ladies and Gentlemen:
Mentor Variable Investment Portfolios (the "Trust") hereby applies,
pursuant to paragraph (a) of Rule 477 under the Securities Act of 1933, as
amended, to withdraw the above-captioned Post-effective Amendment to its
Registration Statement on Form N-1A filed with the Commission on January 29,
1999.
As discussed by the Trust's counsel with Mr. Ronald A. Hollensky of the
Commission staff, the Trust believes that the withdrawal is in the best interest
of the Trust and in the public interest, in light of the pending effectiveness
of its Post-effective Amendment No. 2, which contains disclosures regarding the
VIP High Income Portfolio. The Trust hereby confirms its understanding based on
discussions of its counsel with Mr. Hollensky that its Post-effective Amendment
No. 2 will become effective on May 3, 1999, with respect to all of the Trust's
Portfolios named therein including the VIP High Income Portfolio.
Very truly yours,
/s/ Paul F. Costello
Paul F. Costello
President
