VICTORY VARIABLE INSURANCE FUNDS
497J, 2000-05-03
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                      The Victory Variable Insurance Funds
                                3435 Stelzer Road
                              Columbus, Ohio 43219

                                  May 3, 2000


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 prospectuses 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. 2 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 April 27, 2000.

      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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