EX-99.77B ACCT LTTR 10 auditor.htm









REPORT OF INDEPENDENT REGISTERED PUBLIC
ACCOUNTING FIRM

To the Shareholders and Board of Trustees of
Morgan Stanley Variable Investment Series:

In planning and performing our audit of the financial statements of
Morgan Stanley Variable Investment Series (the Fund) comprising
Money Market Portfolio, Limited Duration Portfolio, Income Plus
Portfolio (formerly Quality Income Plus Portfolio), High Yield
Portfolio, Utilities Portfolio, Income Builder Portfolio, Dividend
Growth Portfolio, Global Dividend Growth Portfolio, European Equity
Portfolio, Equity Portfolio, S&P 500 Index Portfolio, Global
Advantage Portfolio, Aggressive Equity Portfolio, Information
Portfolio, and Strategist Portfolio (the “Portfolios”) as of and for the
year ended December 31, 2005, in accordance with the standards of the
Public Company Accounting Oversight Board (United States), we
considered its internal control over financial reporting, including
control activities for safeguarding securities, as a basis for designing
our auditing procedures for the purpose of expressing our opinion on
the financial statements and to comply with the requirements of Form
N-SAR, but not for the purpose of expressing an opinion on the
effectiveness of the Fund’s internal control over financial reporting.
Accordingly, we express no such opinion.

The management of the Fund is responsible for establishing and
maintaining effective internal control over financial reporting.  In
fulfilling this responsibility, estimates and judgments by management
are required to assess the expected benefits and related costs of
controls.  A fund’s internal control over financial reporting is a process
designed to provide reasonable assurance regarding the reliability of
financial reporting and the preparation of financial statements for
external purposes in accordance with generally accepted accounting
principles.  Such internal control includes policies and procedures that
provide reasonable assurance regarding prevention or timely detection
of unauthorized acquisition, use, or disposition of a fund’s assets that
could have a material effect on the financial statements.

Because of its inherent limitations, internal control over financial
reporting may not prevent or detect misstatements. Also, projections of
any evaluation of effectiveness to future periods are subject to the risk
that controls may become inadequate because of changes in conditions
or that the degree of compliance with the policies or procedures may
deteriorate.

A control deficiency exists when the design or operation of a control
does not allow management or employees, in the normal course of
performing their assigned functions, to prevent or detect misstatements
on a timely basis. A significant deficiency is a control deficiency, or
combination of control deficiencies, that adversely affects the fund’s
ability to initiate, authorize, record, process, or report financial data
reliably in accordance with generally accepted accounting principles
such that there is more than a remote likelihood that a misstatement of
the fund’s annual or interim financial statements that is more than
inconsequential will not be prevented or detected. A material weakness
is a significant deficiency, or combination of significant deficiencies,
that results in more than a remote likelihood that a material
misstatement of the annual or interim financial statements will not be
prevented or detected.

Our consideration of the Fund’s internal control over financial
reporting was for the limited purpose described in the first paragraph
and would not necessarily disclose all deficiencies in internal control
that might be significant deficiencies or material weaknesses under
standards established by the Public Company Accounting Oversight
Board (United States).  However, we noted no deficiencies in the
Fund’s internal control over financial reporting and its operation,
including controls for safeguarding securities, that we consider to be a
material weakness as defined above as of December 31, 2005.

This report is intended solely for the information and use of
management and the Board of Trustees of Morgan Stanley Variable
Investment Series and the Securities and Exchange Commission and is
not intended to be and should not be used by anyone other than these
specified parties.


New York, New York
February 22, 2006