First Amendment to Investment Subadvisory Agreement

Exhibit 99.28(d)(vii)(1)

First Amendment to

Investment Subadvisory Agreement

First Amendment dated February 9, 2021 to the Investment Subadvisory Agreement dated February 1, 2021 (the “Agreement”) made by and among Global Atlantic Investment Advisors, LLC, a Delaware limited liability company (the “Investment Adviser”), Forethought Variable Insurance Trust, a Delaware statutory trust (the “Trust”), on behalf of its series, Global Atlantic Wellington Research Managed Risk Portfolio (the “Fund”), and Wellington Management Company LLP (the “Subadviser”). Capitalized terms used herein and not otherwise defined shall have the definition set out in the Agreement.

In accordance with Section 13 of the Agreement, effective February 1, 2021, the parties hereby amend the Agreement as follows:

1. Section 3 of the Agreement is deleted and replaced in its entirety with the following:

Compensation of Subadviser. As compensation for all investment advisory and management services to be rendered hereunder, the Investment Adviser will pay the Subadviser an annual fee, computed daily and paid quarterly in arrears, which varies in accordance with the net asset value of the Fund. The annual subadvisory fee is expressed as a percent of the average daily net assets of the Fund as follows:

[Insert Fee Schedule]

For any period less than a full fiscal quarter during which this Agreement is in effect, the fee shall be prorated according to the proportion which such period bears to a full fiscal quarter. The Subadviser’s fee shall be payable solely by the Investment Adviser. The Fund shall have no responsibility for such fee.

For purposes hereof, the value of net assets of the Fund shall be computed in the manner specified in the Fund’s Prospectus and Statement of Additional Information for the computation of the value of the net assets of the Fund in connection with the determination of net asset value of its shares. On any day that the net asset value determination is suspended as specified in the Fund’s Prospectus, the net asset value for purposes of calculating the advisory fee shall be calculated as of the date last determined.

[Signature Page Follows]

IN WITNESS WHEREOF, the undersigned parties have executed this Agreement to be effective upon the date above.

Forethought Variable Insurance Trust

By its authorized officer,

By:

Name:

Title:

Global Atlantic Investment Advisors, LLC

By its authorized officer,

By:

Name:

Title:

Wellington Management Company LLP

By its authorized officer,

By:

Name:

Title: