VICTORY VARIABLE FUNDS
N-8A, 1998-08-21
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                       SECURITIES AND EXCHANGE COMMISSION
                             Washington, D.C. 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:    The Victory Variable Funds

Address of Principal Business Offices (No. & Street, City, State, Zip Code):
                  3435 Stelzer Road
                  Columbus, Ohio  43219

Telephone Number (including area code):   (800) 539-3863


Name and address of agent for service of process:
                  Jay G. Baris, Esq.
                  Kramer, Levin, Naftalis & Frankel
                  919 Third Avenue
                  New York, New York  10022

Check Appropriate Box:

         Registrant is filing a Registration  Statement pursuant to Section 8(b)
of the Investment Company Act of 1940 concurrently with the filing of Form N-8A:
Yes [X] 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 of the city of New York and state of New York on the 21st day of  August,
1998.

                                    Signature       The Victory Variable Funds
                                                       (Name of Registrant)


                                                     By: /s/ William B. Blundin
                                                         ----------------------
                                                         William B. Blundin
                                                         Trustee




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