IVY FUNDS VARIABLE INSURANCE PORTFOLIOS

6300 LAMAR AVENUE

P. O. BOX 29217

SHAWNEE MISSION, KANSAS 66201-9217

August 23, 2010

Securities and Exchange Commission

100 F Street NE

Washington DC 20549

Re: Ivy Funds Variable Insurance Portfolios (Registrant)

File Nos. 811-5017 and 33-11466/CIK #810016

We are hereby transmitting for filing through EDGAR Post-Effective Amendment No. 53 (Amendment) to the Registration Statement under the Securities Act of 1933 and Amendment No. 53 of the Investment Company Act of 1940 for the above-referenced Registrant. This transmission contains a conformed signature page, a conformed opinion of counsel and the conformed consent of the Registrant’s independent registered public accounting firm. The manually signed originals of these documents are maintained at the offices of the Registrant.

The Amendment reflects non-material language, organizational and editorial changes, as well as changes made in response to comments issued by the Registrant’s examiner regarding the establishment of two (2) new series of the Registrant: Ivy Funds VIP Global Bond and Ivy Funds VIP Limited-Term Bond (the “Portfolios”). This filing is being made pursuant to paragraph (b) of Rule 485. It is proposed that this filing will become effective on August 23, 2010.

In connection with the filing of this Amendment, I hereby represent that the Amendment does not contain disclosures which would render it ineligible to become effective pursuant to paragraph (b) of Rule 485.

If you have any questions or comments concerning the foregoing, please contact me at 913-236-1923.

Very truly yours,

/s/Kristen A. Richards

Kristen A. Richards

Vice President, Associate General Counsel

and Assistant Secretary