VICTORY VARIABLE INSURANCE FUNDS
497J, 1999-07-07
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                      The Victory Variable Insurance Funds
                                3435 Stelzer Road
                              Columbus, Ohio 43219

                                  July 6, 1999


VIA EDGAR
- ---------

Securities and Exchange Commission
450 Fifth Street, N.W., Judiciary Plaza
Washington, D.C. 20549

                  Re:      The Victory Variable Insurance Funds
                           File Nos. 333-62051; 811-8979; CIK: 0001068663
                           ----------------------------------------------

Ladies and Gentlemen:

         On behalf of The Victory Variable  Insurance Funds  ("Registrant")  and
pursuant  to Rule  497(j)  under the  Securities  Act of 1933,  as amended  (the
"Securities  Act"),  I hereby certify that (i) the prospectus for the Investment
Quality Bond Fund, the Diversified Stock Fund and the Small Company  Opportunity
Fund,  each a series of Registrant,  that would have been filed pursuant to Rule
497(c) under the  Securities  Act would not have differed from that contained in
Post-Effective  Amendment No. 1 to Registrant's  Registration  Statement on Form
N-1A  ("the  Amendment"),   constituting  the  most  recent  amendment  to  this
Registration   Statement;   and  (ii)  the  text  of  the  Amendment  was  filed
electronically with the Securities and Exchange Commission on July 1, 1999.

         If you have any  questions or comments  regarding  this filing,  please
call George P. Attisano at (212) 715-9289.

                                            Very truly yours,


                                            The Victory Variable Insurance Funds


                                                     By:  /s/ Joel B. Engle
                                                          -----------------
                                                          Joel B. Engle
                                                          Treasurer



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