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Wells Fargo Funds Management, LLC
525 Market Street, 12th Floor
San Francisco, CA 94105
April 2, 2009
VIA EDGAR CORRESPONDENCE AND ELECTRONIC MAIL
Ms. Michele Roberts, Esq.
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
| Re: | Wells Fargo Advantage VT International Core Fund | ||
| Wells Fargo Variable Trust |
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| File Nos. 33-74283 and 811-09255 |
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Dear Ms. Roberts:
The purpose of this letter is to address an additional comment from you regarding Post-Effective Amendment No. 22 to the Trust’s Registration Statement on Form N-1A, as filed on March 12, 2009, on behalf of the Wells Fargo Advantage VT International Core Fund (the “Fund”). This letter should be considered in addition to our letter to you dated April 2, 2009. The numbering of the comment as “Comment 3” reflects the cumulative nature of our response.
Comment 3:
You requested that we reconsider the use of the term “insurance costs” in the following sentence on page 18 of the prospectus for the Fund, and potentially substitute “sales charges” for such term:
“Over time, these fees will increase the cost of your investment and may cost you more than paying other types of insurance costs.”
Ms. Michele Roberts
April 2, 2009
Page 2
Response to Comment 3:
In response to your comment, we have changed the language of the sentence in question to read as follows:
“Over time, these fees will increase the cost of your investment and may cost you more than paying other types of sales charges.”
Conclusion
The Fund accepts responsibility for the adequacy and accuracy of the disclosure in the filings that are the subject of this letter. The Fund acknowledges that staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff do not foreclose the Securities and Exchange Commission from taking any action with respect to these filings. The Fund further acknowledges that it may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
We trust that the above response adequately addresses your comments and suggestions. If you need additional information, please do not hesitate to contact me at 415-947-4805.
WELLS FARGO FUNDS MANAGEMENT, LLC
By: /s/ Lawrence S. Hing
| Lawrence S. Hing | |
| Senior Counsel |
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cc: | C. David Messman |
Marco Adelfio
