November 1, 2007


VIA EDGAR
---------

Securities and Exchange Commission
100 F Street, NE
Washington, D.C.  20549
Attn:  Ms. Sally Samuel

         Re:      Wilshire Variable Insurance Trust (the "Registrant")
                  File Numbers 333-15881 and 811-07917
                  ----------------------------------------------------

Dear Ms. Samuel:

         This letter is provided to the Securities and Exchange  Commission (the
"Commission")  in  connection  with a  response  being  made  on  behalf  of the
Registrant  to  comments   that  you  provided  with  respect  to   Registrant's
preliminary information statement filed with the Commission on October 17, 2007.

         The  Registrant  acknowledges  that the  adequacy  and  accuracy of the
disclosure  in  such  filing  is  the  responsibility  of  the  Registrant.  The
Registrant acknowledges that any comments or changes to disclosure in the filing
reviewed by the Commission staff, acting pursuant to delegated authority, do not
foreclose the  Commission  from taking any action with respect to the filing and
the Registrant represents that it will not assert staff comments as a defense in
any  proceeding  initiated  by the  Commission  or any person  under the federal
securities laws of the United States.

Very truly yours,


WILSHIRE VARIABLE INSURANCE TRUST


By:  /s/ Helen Thompson
     -----------------------------------
     Name:  Helen Thompson
     Title:  Chief Compliance Officer