VICTORY VARIABLE INSURANCE FUNDS
N-18F1, 1998-10-23
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                                  Form N-18F-1







                       SECURITIES AND EXCHANGE COMMISSION
                             Washington, D.C. 20549













                 NOTIFICATION OF ELECTION PURSUANT TO RULE 18f-1
                    UNDER THE INVESTMENT COMPANY ACT OF 1940












                      THE VICTORY VARIABLE INSURANCE FUNDS
                      ------------------------------------
                            Exact Name of Registrant


                            c/o Bisys Fund Services
                               3435 Stelzer Road
                               Columbus, OH 43219
                      -------------------------------------
                      Address of Principal Executive Officer


                                 1-800-539-3863
                         ------------------------------
                         Area Code and Telephone Number


<PAGE>
                            NOTIFICATION OF ELECTION

                  The undersigned  registered open-end investment company hereby
notifies the Securities and Exchange  Commission that it elects to commit itself
to pay in cash all  redemptions  by a shareholder  of record as provided by Rule
18f-1 under the Investment  Company Act of 1940, as amended (the "1940 Act"). It
is  understood  that this election is  irrevocable  while such Rule is in effect
unless the  Commission  order upon  application  permits the  withdrawal of this
Notification of Election.

                                    SIGNATURE

                  Pursuant to the requirements of Rule 18f-1 under the 1940 Act,
the Registrant has caused this  notification  of election to be duly executed on
its  behalf in the City of New York and the State of New York on the 15th day of
October, 1998.

      Signature:                            THE VICTORY VARIABLE INSURANCE FUNDS
                                            (Name of Registrant)

                                            By:  /s/ Michael Sullivan
                                                 ------------------------------
                                                 Name: Michael Sullivan
                                                       -------------------------
                                                 Title:  Secretary
                                                         -----------------------

Attest:   /s/ Alaina V. Metz
          -----------------------
     Name:  Alaina V. Metz
            ---------------------
     Title:  Assistant Secretary
             --------------------


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