i:\legal\sec.reg\edgar\24f2\24f2vist.doc
FORM 24F-2
Annual Notice of Securities Sold
Pursuant to Rule 24f-2
1. Name and address of issuer:
Variable Investors Series Trust
10 Post Office Square
Boston, MA 02109
2. Name of each series or class of funds for which this notice is
filed:
3. Investment Company Act File Number: 811-4969
Securities Act file Number: 33-11182
4. Last day of fiscal year for which this notice is filed: December
31, 1996
5. Check box if this notice is being filed more than 180 days after
the close of the issuer's fiscal year for purposes of reporting
securities sold after the close of the fiscal year but before
termination of the issuer's 24f-2's declaration:
6. Date of termination of issuer's declaration under rule
24f-2(a)(1), if applicable (see Instruction A.6):
7. Number and amount of securities of the same class or series which
had been registered under the Securities Act of 1933 other than
pursuant to rule 24f-2 in a prior fiscal year, but which remained
unsold at the beginning of the fiscal year:
Number: 0 Amount: $0
8. Number and amount of securities registered during the fiscal year
other than pursuant to rule 24f-2:
Number: 0 Amount: $0
9. Number and aggregate sale price of securities sold during the
fiscal year:
Number: 1,347,152 Amount: $2,782,515
10. Number and aggregate sale price of securities sold during the
fiscal year in reliance upon registration pursuant to rule 24f-2:
Number: 1,347,152 Amount: $2,782,515
11. Number and aggregate sale price of securities issued during the
fiscal year in connection with dividend reinvestment plans, if
applicable (see Instruction B.7):
Number: 0 Amount: $0
12. Calculation of registration fee:
(i) Aggregate sale price of securities sold during the fiscal
year in reliance on rule 24f-2 (from Item 10):
$ 2,782,515
(ii) Aggregate price of shares issued in connection with dividend
reinvestment plans from Item 11, if applicable):
+ 0
(iii) Aggregate price of shares redeemed or repurchased during
the fiscal year (if applicable)
- 2,782,515
(iv) Aggregate price of shares redeemed or repurchased and
previously applied as a reduction to filing fees pursuant to rule
24e-2 (if applicable):
+ 0
(v) Net aggregate price of securities sold and issued during the
fiscal year in reliance on rule 24f-2 [line (I), plus line (ii),
less line (iii), plus line (iv)] (if applicable):
0
(vi) Multiplier prescribed by Section 6(b) of the Securities Act
of 1933 or other applicable law or regulation (see Instruction
C.6):
x 1/3300
(vii) Fee due [line (I) or line (v) multiplied by line (vi)]:
0
Instruction: Issuers should complete line (ii), (iii), (iv), and (v)
only if from is being filed within 60 days after the close of the
issuer's fiscal year. Instruction C.3.
13. Check box if fees are being remitted to the Commission's lockbox
depository as described in section 3a of the Commission's Rules
of Informal and Other Procedures (17CFR 202.3a).
Date of mailing or wire transfer of filing fees to the
Commission's lockbox depository: not applicable
<PAGE>
SIGNATURES
This report has been signed below the following persons on behalf of
the issuer and in the capacities and on the dates indicated.
By (Signature and Title)*
______S/Arnold R. Bergman__________________
Secretary
Date:February 27, 1997
*Please print the name and title of the signing officer below the
signature
<PAGE>
Blazzard, Grodd & Hasenauer, P.C.
943 Post Road East
Westport, CT 06880
(203) 226-7866
February 24, 1997
Board of Trustees
Variable Investors Series Trust
10 Post Office Square
Boston, MA 02109
RE: Opinion of Counsel - Variable Investors Series Trust
Gentlemen:
You have requested our Opinion of Counsel in connection with the filing
with the Securities and Exchange Commission of Form 24F-2 with respect
to Variable Investors Series Trust.
We have made such examination of the law and have examined such records
and documents as in our judgment are necessary or appropriate to enable
us to render the opinions expressed below.
We are of the following opinions:
1. Variable Investors Series Trust ("Trust") is a valid and
existing unincorporated voluntary association, commonly known as a
business trust. The Trust is a business trust created and validly
existing pursuant to Massachusetts Laws.
2. Upon the acceptance of purchase payments made by
shareholders in accordance with the Prospectus contained in the
Registration Statement and upon compliance with applicable law, such
shareholders will have legally-issued, fully paid, non-assessable
shares of the Trust.
This opinion is limited solely to its use as an exhibit to your Form
24F-2 filed pursuant to Rule 24f-2.
Sincerely,
BLAZZARD, GRODD & HASENAUER, P.C.
By: /S/ RAYMOND A. O'HARA III
_____________________________
Raymond A. O'Hara III
