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BARR ROSENBERG VARIABLE INSURANCE TRUST
C/O AXA ROSENBERG INVESTMENT MANAGEMENT LLC
4 ORINDA WAY, BUILDING E
ORINDA, CALIFORNIA 94563
925-254-6464
April 5, 1999
ELECTRONIC SUBMISSION - VIA EDGAR
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Division of Investment Management
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549
ATTN: Kevin Circhoff
Re: Barr Rosenberg Variable Insurance Trust (the "Trust")
(Registration Nos. 333-50529 and 811-08759) - Post Effective
Amendment No. 2
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Ladies and Gentlemen:
Pursuant to paragraph (a) of Rule 477 (the "Rule") under the Securities Act
of 1933, as amended, I hereby request on behalf of the Trust that the Commission
withdraw Post-Effective Amendment No. 2 (the "Amendment") to the Trust's
Registration Statement on Form N-1A. The Amendment was filed with the
Securities and Exchange Commission (the "Commission") on February 16, 1999 to
add a new series, the Barr Rosenberg VIT Select Sectors Market Neutral Fund, to
the Trust.
The Trust has no present intention of initiating operations or offering
shares of the Barr Rosenberg VIT Select Sectors Market Neutral Fund and would
like to avoid costs associated with adding the series at this time. The
Amendment would make no other material changes to the Trust's currently
effective registration statement. Accordingly, the Trust believes that
withdrawing the Amendment at this time would be consistent with the public
interest and the protection of investors in accordance with the Rule.
The Amendment's expected effective date is May 2, 1999. Accordingly,
please notify me of your decision at your earliest convenience before that date.
If the Commission consents to the withdrawal, I would request that copies of the
Commission's order granting the withdrawal be forwarded to my attention and to
the attention of John McGinty, Ropes & Gray, One International Place, Boston, MA
02110-2624. Please direct any questions you may have with respect to this
application to me at the number indicated above or, in my absence, to John
McGinty (617-951-7569) or J.B. Kittredge (617-951-7392) of Ropes & Gray.
BARR ROSENBERG VARIABLE INSURANCE
TRUST
KENNETH REID
Kenneth Reid
President and Agent for Service of Process
JBM/laf:3384422.01
cc: Edward H. Lyman, Esq.
J.B. Kittredge, Jr., Esq.
Byung W. Choi, Esq.
John B. McGinty, Jr., Esq.
