SUB-ITEM 77D
MFS VARIABLE INSURANCE TRUST
This document is hereby incorporated to this N-SAR filing by reference: Each of
the following series (outlined below) within this Trust have made material
changes in the prospectus and statement of additional information with respect
to investment policy as incorporated by reference to Registrant's Post-Effective
Amendment No. 14 (File Nos. 33-74668 and 811-8326) as filed with the SEC via
EDGAR on February 11, 2000.
o MFS Emerging Growth Series (VEG) - added disclosure permitting an
investment percentage limitation of 25% in foreign securities (including
emerging markets).
o MFS Capital Opportunities Series (VVS) - added disclosure for active or
frequent trading. o MFS Total Return Series (VTR) - added disclosure for
investing in foreign securities.
o MFS Utilities Series (VUF) - added disclosure for active or frequent trading,
investing in junk bonds and emerging markets. o MFS High Income Series (VHI) -
added disclosure for active or frequent trading. o MFS Global Governments Series
(VWG) - added disclosure for active or frequent trading. o MFS Bond Series (VFB)
- added disclosure for investing in foreign securities and for active or
frequent trading. o MFS Money Market Series (VMM) - added disclosure for
investing in municipal securities. o MFS New Discovery Series (VND) - added
disclosure for investing in short sales and for active or frequent trading.
