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June 18, 2020
Securities and Exchange Commission
Division of Investment Management
Office of Insurance Products
100 F Street NE
Washington, DC 20549
Re: Registration Statement on Form N-14 for Combination of a Series of the Allianz Variable Insurance Products Trust (the "Trust") (SEC File Nos. 333-83423 and 811-09491) with and into another Series of the Trust
Dear Sir/Madam:
Accompanying this letter for filing is one copy of the Trust's Registration Statement on Form N-14. This registration statement relates to the proposed combination of a series of the Trust with and into another series of the Trust. Exhibits not included in this filing will be filed by amendment.
Pursuant to Form N-14, General Instruction B, and Rule 24f-2, no filing fee is due upon the filing of this registration statement.
Pursuant to Rule 488 under the Securities Act of 1933, as amended, this registration statement will become effective automatically on the thirtieth day after the date upon which it is filed.
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