REPORT OF INDEPENDENT REGISTERED PUBLIC
ACCOUNTING FIRM
To the Board of Trustees of MFS Variable Insurance
Trust II and the Shareholders of MFS Blended Research
Core Equity Portfolio, MFS Core Equity Portfolio, MFS
Corporate Bond Portfolio, MFS Emerging Markets
Equity Portfolio, MFS Global Governments Portfolio,
MFS Global Growth Portfolio, MFS Global Research
Portfolio, MFS Global Tactical Allocation Portfolio, MFS
Government Securities Portfolio, MFS High Yield
Portfolio, MFS International Growth Portfolio, MFS
International Value Portfolio, MFS Massachusetts
Investors Growth Stock Portfolio , MFS Research
International Portfolio, MFS Strategic Income Portfolio,
MFS Technology Portfolio and MFS U.S. Government
Money Market Portfolio (collectively, the "Funds"):
In planning and performing our audits of the financial
statements of the Funds as of and for the year ended
December 31, 2018, in accordance with the standards
of the Public Company Accounting Oversight Board
(United States), we considered the Funds' internal
control over financial reporting, including controls over
safeguarding securities, as a basis for designing our
auditing procedures for the purpose of expressing our
opinions on the financial statements and to comply with
the requirements of Form N-CEN, but not for the
purpose of expressing an opinion on the effectiveness
of the Funds' internal control over financial reporting.
Accordingly, we express no such opinion.
The management of the Funds 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. A fund's internal control over
financial reporting includes those policies and
procedures that (1) pertain to the maintenance of
records that, in reasonable detail, accurately and fairly
reflect the transactions and dispositions of the assets of
the fund; (2) provide reasonable assurance that
transactions are recorded as necessary to permit
preparation of financial statements in accordance with
generally accepted accounting principles, and that
receipts and expenditures of the fund are being made
only in accordance with authorizations of management
of the fund and trustees of the trust; and (3) 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 deficiency in internal control over financial reporting
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
material weakness is a deficiency, or a combination of
deficiencies, in internal control over financial reporting,
such that there is a reasonable possibility that a
material misstatement of a fund's annual or interim
financial statements will not be prevented or detected
on a timely basis.
Our consideration of the Funds' 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 material weaknesses under standards
established by the Public Company Accounting
Oversight Board (United States). However, we noted no
deficiencies in the Funds' internal control over financial
reporting and their operation, including controls for
safeguarding securities, that we consider to be a
material weakness, as defined above, as of December
31, 2018.
This report is intended solely for the information and
use of management, the Board of Trustees of MFS
Variable Insurance Trust II and the Securities and
Exchange Commission and is not intended to be and
should not be used by anyone other than these
specified parties.

DELOITTE & TOUCHE LLP

Boston, Massachusetts
February 15, 2019