Exhibit (i)

August 23, 2010

SECURITIES AND EXCHANGE COMMISSION

100 F Street, NE

Washington, DC 20549

Re: Ivy Funds Variable Insurance Portfolios

Post-Effective Amendment No. 53

Dear Sir or Madam:

In connection with the public offering of Trust Shares of Ivy Funds Variable Insurance Portfolios (the Registrant), I have examined such corporate records and documents and have made such further investigation and examination as I deemed necessary for the purpose of this opinion.

It is my opinion that the indefinite number of such Trust Shares covered by the Registrant’s Registration Statement on Form N-1A, when issued and paid for in accordance with the terms of the offering, as set forth in the Prospectus and Statement of Additional Information forming a part of the Registration Statement, will be, when such Registration shall have become effective, legally issued, fully paid and non-assessable by the Registrant.

I hereby consent to the filing of this opinion as an Exhibit to the Registration Statement and to the reference to me in such Statement of Additional Information.

Yours truly,

/s/Kristen A. Richards

Kristen A. Richards

Vice President, Assistant Secretary

and Associate General Counsel