![](https://capedge.com/proxy/N-14A/0001091439-16-000074/image1.jpg)
August 16, 2016
Securities and Exchange Commission
Division of Investment Management
Office of Insurance Products
100 F Street NE
Washington, DC 20549
Re: Pre-Effective Amendment No. 1 to the Registration Statements on Form N-14 (File Nos. 333-212555, 333-212556, 333-212557, 333-212558, 333-212559, and 333-212560) for Combination of Certain Series of the Allianz Variable Insurance Products Trust (the "Trust") (SEC File Nos. 333-83423 and 811-09491) with and into Corresponding Series of the Trust
Dear Sir/Madam:
Accompanying this letter for filing is Pre-Effective Amendment No. 1 of the Trust's Registration Statement on Form N-14. This registration statement relates to the proposed combination of certain series of the Trust with and into corresponding series of the Trust. All changes related to staff comments previously provided are reflected in this Amendment as described in the response letter submitted separately.
Pursuant to Rule 461 under the Securities Act of 1933, the Registrant and its principal underwriter, Allianz Life Financial Services, LLC, respectfully request that the effective date of the Registration Statement be accelerated and that the Registration Statement be declared effective August 17, 2016, or as soon thereafter as may be practicable.
In connection with this filing, the Registrant acknowledges that the Registrant is responsible for the adequacy and accuracy of the disclosure in this filing. Staff comments on the filing, changes to the filing following staff comments or any action by the Commission or by the staff of the Commission, acting pursuant to delegated authority, to declare the filing effective do not foreclose the Commission from taking any action with respect to the filing. The Registrant cannot assert staff comments as a defense to an action by the Commission under the Federal securities laws except to the extent otherwise legally permissible.
Manually executed signature pages and consents have been executed prior to the time of this electronic filing and will be retained by the Registrant for five years. Any disclosures and exhibits not filed herewith will be filed in a subsequent 485(b) filing. Pursuant to Form N-14, General Instruction B, and Rule 24f-2, no filing fee is due upon the filing of this registration statement. If you have any questions or comments, please feel free to contact the undersigned.
Sincerely,
Allianz Variable Insurance Products Trust
By: /s/ Erik Nelson
______________________________________________
Erik Nelson, Chief Legal Officer
763/765-7453
Erik.Nelson@allianzlife.com
Allianz Life Financial Services, LLC
By: /s/ Kristine M. Lord-Krahn
______________________________________________
Kristine M. Lord-Krahn,
Chief Legal Officer and Secretary