i:\legal\sec.reg\edgar\24f2\24f2vist.doc
                               FORM 24F-2
                    Annual Notice of Securities Sold
                         Pursuant to Rule 24f-2

1.    Name and address of issuer:
                          Variable Investors Series Trust
                          10 Post Office Square
                          Boston, MA 02109

2.    Name of each series or class of funds for which this notice is
filed:



3.    Investment Company Act File Number: 811-4969

      Securities Act file Number:   33-11182

4.    Last day of fiscal year for which this notice is filed: December
31, 1996


5.    Check box if this  notice is being  filed more than 180 days after
      the close of the  issuer's  fiscal year for  purposes of reporting
      securities  sold  after the close of the  fiscal  year but  before
      termination of the issuer's 24f-2's declaration:


6.    Date of termination of issuer's declaration under rule
      24f-2(a)(1), if applicable (see Instruction A.6):


7.    Number and amount of  securities of the same class or series which
      had been  registered  under the  Securities Act of 1933 other than
      pursuant to rule 24f-2 in a prior fiscal year,  but which remained
      unsold at the beginning of the fiscal year:

                Number: 0           Amount: $0

8.    Number and amount of securities registered during the fiscal year
      other than pursuant to rule 24f-2:

                Number: 0           Amount: $0

9.    Number and aggregate sale price of securities sold during the
fiscal year:

                Number: 1,347,152   Amount: $2,782,515

10.   Number and aggregate sale price of securities sold during the
      fiscal year in reliance upon registration pursuant to rule 24f-2:

                Number: 1,347,152   Amount: $2,782,515

11.   Number and aggregate  sale price of  securities  issued during the
      fiscal year in connection  with dividend  reinvestment  plans,  if
      applicable (see Instruction B.7):

                Number: 0           Amount: $0

12.   Calculation of registration fee:

      (i)  Aggregate sale price of securities sold during the fiscal
      year in reliance on rule 24f-2 (from Item 10):
                                               $    2,782,515 
      (ii) Aggregate price of shares issued in connection with dividend
      reinvestment plans from Item 11, if applicable):

                                               +         0    
      (iii) Aggregate price of shares redeemed or repurchased during
      the fiscal year (if applicable)

                                               -    2,782,515 
      (iv) Aggregate price of shares redeemed or repurchased and
      previously applied as a reduction to filing fees pursuant to rule
      24e-2 (if applicable):

                                               +         0    
      (v) Net aggregate price of securities sold and issued during the
      fiscal year in reliance on rule 24f-2 [line (I), plus line (ii),
      less line (iii), plus line (iv)] (if applicable):

                                                         0    
      (vi) Multiplier prescribed by Section 6(b) of the Securities Act
      of 1933 or other applicable law or regulation (see Instruction
      C.6):

                                               x    1/3300    
      (vii) Fee due [line (I) or line (v) multiplied by line (vi)]:

                                                         0    
Instruction:  Issuers should complete line (ii), (iii), (iv), and (v)
only if from is being filed within 60 days after the close of the
issuer's fiscal year.  Instruction C.3.

13.   Check box if fees are being remitted to the Commission's lockbox
      depository as described in section 3a of the Commission's Rules
      of Informal and Other Procedures (17CFR 202.3a).

      Date of mailing or wire transfer of filing fees to the
      Commission's lockbox depository: not applicable


<PAGE>

                               SIGNATURES
This report has been signed below the following persons on behalf of
the issuer and in the capacities and on the dates indicated.

By (Signature and Title)*
 
                ______S/Arnold R. Bergman__________________

                     Secretary                      

Date:February 27, 1997

   *Please print the name and title of the signing officer below the
                               signature

<PAGE>


Blazzard, Grodd & Hasenauer, P.C.
943 Post Road East
Westport, CT  06880
(203) 226-7866


February 24, 1997


Board of Trustees
Variable Investors Series Trust
10 Post Office Square
Boston, MA  02109

RE:   Opinion of Counsel - Variable Investors Series Trust

Gentlemen:

You have requested our Opinion of Counsel in connection with the filing
with the Securities and Exchange Commission of Form 24F-2 with respect
to Variable Investors Series Trust.

We have made such examination of the law and have examined such records
and documents as in our judgment are necessary or appropriate to enable
us to render the opinions expressed below.

We are of the following opinions:

      1.   Variable Investors Series Trust ("Trust") is a valid and
existing unincorporated voluntary association, commonly known as a
business trust.  The Trust is a business trust created and validly
existing pursuant to Massachusetts Laws.

      2.   Upon the acceptance of purchase payments made by
shareholders in accordance  with the Prospectus contained in the
Registration Statement and upon compliance with applicable law, such
shareholders will have legally-issued, fully paid, non-assessable
shares of the Trust.

This opinion is limited solely to its use as an exhibit to your Form
24F-2 filed pursuant to Rule 24f-2.

Sincerely,

BLAZZARD, GRODD & HASENAUER, P.C.


By:  /S/ RAYMOND A. O'HARA III
       _____________________________
      Raymond A. O'Hara III