Rydex Variable Trust
                         9601 Blackwell Road, Suite 500
                            Rockville, Maryland 20850


July 10, 2009


VIA EDGAR
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U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

Attention: Mr. Jeffrey A. Foor

Re:      REQUEST FOR WITHDRAWAL PURSUANT TO RULE 477 UNDER THE SECURITIES ACT OF
         1933 (FILE NO. 333-160176)
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Ladies and Gentleman:

On behalf of Rydex Variable Trust (the  "Trust"),  we request,  pursuant to Rule
477 under the  Securities  Act of 1933  (the  "1933  Act"),  the  withdrawal  of
Post-Effective  Amendment  No. 1 to the Trust's  registration  statement on Form
N-14  (File  No.  333-160176),  which  was filed  with the U.S.  Securities  and
Exchange    Commission   on   June   23,   2009   (via   EDGAR   Accession   No.
0000950123-09-16361)  ("PEA No. 1"). PEA No. 1 is being withdrawn because it was
filed under the wrong EDGAR form type.  The Trust intends on re-filing PEA No. 1
under the correct form type.  No  securities  were sold in  connection  with the
above referenced registration statement.

Should you have any  questions  or  comments,  please do not hesitate to call W.
John McGuire at 202.739.5654 or Sarah Swain at 202.739.5808.

Sincerely,

Rydex Variable Trust



By:   /S/ JOANNA HAIGNEY
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      Joanna Haigney
      Secretary