Morgan Stanley Variable Investment Series
522 Fifth Avenue
New York, NY 10036
March 30, 2010
Securities and Exchange Commission
Judiciary Plaza
100 F Street, NE
Washington, D.C. 20549
Attention: Michael L. Kosoff
Re: Morgan Stanley Variable Investment Series
(File No. 002-82510; 811-03692)
Dear Mr. Kosoff:
In response to your oral comments on March 24, 2010, below please find the fee tables and corresponding footnotes for each portfolio of Morgan Stanley Variable Investment Series.
FEE TABLES:
Aggressive Equity Portfolio
Class X:
Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Advisory fee |
| 0.67 | % |
Distribution and service (12b-1) fees |
| None |
|
Other expenses |
| 0.35 | % |
Total annual Portfolio operating expenses |
| 1.02 | % |
Class Y:
Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Advisory fee |
| 0.67 | % |
Distribution and service (12b-1) fees |
| 0.25 | % |
Other expenses |
| 0.35 | % |
Total annual Portfolio operating expenses |
| 1.27 | % |
Capital Opportunities Portfolio
Class X:
Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Advisory fee |
| 0.42 | % |
Distribution and service (12b-1) fees |
| None |
|
Other expenses |
| 0.13 | % |
Total annual Portfolio operating expenses |
| 0.55 | % |
Class Y:
Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Advisory fee |
| 0.42 | % |
Distribution and service (12b-1) fees |
| 0.25 | % |
Other expenses |
| 0.13 | % |
Total annual Portfolio operating expenses |
| 0.80 | % |
Dividend Growth Portfolio
Class X:
Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Advisory fee |
| 0.54 | % |
Distribution and service (12b-1) fees |
| None |
|
Other expenses |
| 0.13 | % |
Total annual Portfolio operating expenses |
| 0.67 | % |
Class Y:
Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Advisory fee |
| 0.54 | % |
Distribution and service (12b-1) fees |
| 0.25 | % |
Other expenses |
| 0.13 | % |
Total annual Portfolio operating expenses |
| 0.92 | % |
European Equity Portfolio
Class X:
Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Advisory fee |
| 0.87 | % |
Distribution and service (12b-1) fees |
| None |
|
Other expenses |
| 0.25 | % |
Total annual Portfolio operating expenses* |
| 1.12 | % |
Fee waiver and/or expense reimbursement* |
| 0.12 | % |
Total annual Portfolio operating expenses after fee waiver and/or expense reimbursement* |
| 1.00 | % |
* The Portfolio’s “Investment Adviser,” Morgan Stanley Investment Advisors Inc., is currently waiving or reimbursing all or a portion of the Portfolio’s advisory fees and/or other expenses (excluding brokerage fees). The fee waivers and/or expense reimbursements are expected to continue (such that the Total annual Portfolio operating expenses after fee waiver and/or expense reimbursement do not exceed those amounts listed above) until such time that the Fund’s Board of Trustees acts to discontinue such waivers and/or reimbursements when it deems such action is appropriate.
Class Y:
Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Advisory fee |
| 0.87 | % |
Distribution and service (12b-1) fees |
| 0.25 | % |
Other expenses |
| 0.25 | % |
Total annual Portfolio operating expenses* |
| 1.37 | % |
Fee waiver and/or expense reimbursement* |
| 0.12 | % |
Total annual Portfolio operating expenses after fee waiver and/or expense reimbursement* |
| 1.25 | % |
* The Portfolio’s “Investment Adviser,” Morgan Stanley Investment Advisors Inc., is currently waiving or reimbursing all or a portion of the Portfolio’s advisory fees and/or other expenses (excluding distribution and service (12b-1) fees and brokerage fees). The fee waivers and/or expense reimbursements are expected to continue (such that the Total annual Portfolio operating expenses after fee waiver and/or expense reimbursement do not exceed those amounts listed above) until such time that the Fund’s Board of Trustees acts to discontinue such waivers and/or reimbursements when it deems such action is appropriate.
Global Dividend Growth Portfolio
Class X:
Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Advisory fee |
| 0.67 | % |
Distribution and service (12b-1) fees |
| None |
|
Other expenses |
| 0.26 | % |
Total annual Portfolio operating expenses |
| 0.93 | % |
Class Y:
Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Advisory fee |
| 0.67 | % |
Distribution and service (12b-1) fees |
| 0.25 | % |
Other expenses |
| 0.26 | % |
Total annual Portfolio operating expenses |
| 1.18 | % |
Global Infrastructure Portfolio
Class X:
Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Advisory fee |
| 0.57 | % |
Distribution and service (12b-1) fees |
| None |
|
Other expenses |
| 0.39 | % |
Total annual Portfolio operating expenses |
| 0.96 | % |
Class Y:
Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Advisory fee |
| 0.57 | % |
Distribution and service (12b-1) fees |
| 0.25 | % |
Other expenses |
| 0.39 | % |
Total annual Portfolio operating expenses |
| 1.21 | % |
High Yield Portfolio
Class X:
Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Advisory fee |
| 0.42 | % |
Distribution and service (12b-1) fees |
| None |
|
Other expenses |
| 1.33 | % |
Total annual Portfolio operating expenses |
| 1.75 | % |
Class Y:
Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Advisory fee |
| 0.42 | % |
Distribution and service (12b-1) fees |
| 0.25 | % |
Other expenses |
| 1.33 | % |
Total annual Portfolio operating expenses |
| 2.00 | % |
Income Builder Portfolio
Class X:
Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Advisory fee |
| 0.67 | % |
Distribution and service (12b-1) fees |
| None |
|
Other expenses |
| 0.35 | % |
Total annual Portfolio operating expenses |
| 1.02 | % |
Class Y:
Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Advisory fee |
| 0.67 | % |
Distribution and service (12b-1) fees |
| 0.25 | % |
Other expenses |
| 0.35 | % |
Total annual Portfolio operating expenses |
| 1.27 | % |
Income Plus Portfolio
Class X:
Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Advisory fee |
| 0.42 | % |
Distribution and service (12b-1) fees |
| None |
|
Other expenses |
| 0.14 | % |
Total annual Portfolio operating expenses |
| 0.56 | % |
Class Y:
Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Advisory fee |
| 0.42 | % |
Distribution and service (12b-1) fees |
| 0.25 | % |
Other expenses |
| 0.14 | % |
Total annual Portfolio operating expenses |
| 0.81 | % |
Limited Duration Portfolio
Class X:
Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Advisory fee |
| 0.30 | % |
Distribution and service (12b-1) fees |
| None |
|
Other expenses |
| 0.19 | % |
Total annual Portfolio operating expenses |
| 0.49 | % |
Class Y:
Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Advisory fee |
| 0.30 | % |
Distribution and service (12b-1) fees |
| 0.25 | % |
Other expenses |
| 0.19 | % |
Total annual Portfolio operating expenses |
| 0.74 | % |
Money Market Portfolio
Class X:
Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Advisory fee |
| 0.45 | % |
Distribution and service (12b-1) fees |
| None |
|
Other expenses |
| 0.11 | % |
Total annual Portfolio operating expenses* |
| 0.56 | % |
Fee waiver and/or expense reimbursement* |
| 0.19 | % |
Total annual Portfolio operating expenses after fee waiver and/or expense reimbursement* |
| 0.37 | % |
* The Portfolio’s “Investment Adviser,” Morgan Stanley Investment Advisors Inc., is currently waiving or reimbursing all or a portion of the Portfolio’s advisory fees and/or other expenses to the extent that total expenses exceed total income on a daily basis. The fee waivers and/or expense reimbursements are expected to continue until such time as the Fund’s Board of Trustees acts to discontinue all or a portion of such waivers and/or expense reimbursements when it deems such action is appropriate.
Class Y:
Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Advisory fee |
| 0.45 | % |
Distribution and service (12b-1) fees |
| 0.25 | % |
Other expenses |
| 0.11 | % |
Total annual Portfolio operating expenses* |
| 0.81 | % |
Fee waiver and/or expense reimbursement* |
| 0.43 | % |
Total annual Portfolio operating expenses after fee waiver and/or expense reimbursement* |
| 0.38 | % |
* The Portfolio’s “Investment Adviser,” Morgan Stanley Investment Advisors Inc., is currently waiving or reimbursing all or a portion of the Portfolio’s advisory fees and/or other expenses to the extent that total expenses exceed total income on a daily basis. The fee waivers and/or expense reimbursements are expected to continue until such time as the Fund’s Board of Trustees acts to discontinue all or a portion of such waivers and/or expense reimbursements when it deems such action is appropriate.
S&P 500 Index Portfolio
Class X:
Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Advisory fee |
| 0.12 | % |
Distribution and service (12b-1) fees |
| None |
|
Other expenses |
| 0.16 | % |
Total annual Portfolio operating expenses |
| 0.28 | % |
Class Y:
Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Advisory fee |
| 0.12 | % |
Distribution and service (12b-1) fees |
| 0.25 | % |
Other expenses |
| 0.16 | % |
Total annual Portfolio operating expenses |
| 0.53 | % |
Strategist Portfolio
Class X:
Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Advisory fee |
| 0.42 | % |
Distribution and service (12b-1) fees |
| None |
|
Other expenses |
| 0.16 | % |
Total annual Portfolio operating expenses |
| 0.58 | % |
Class Y:
Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Advisory fee |
| 0.42 | % |
Distribution and service (12b-1) fees |
| 0.25 | % |
Other expenses |
| 0.16 | % |
Total annual Portfolio operating expenses |
| 0.83 | % |
If you would like to discuss this matter in further detail or if you have any questions, please feel free to contact me at (212) 296-6989 (tel) or (646) 290.2042 (fax). Thank you.
Best regards,
/s/ Sheri Schreck |
|
Sheri Schreck |
|