 | Stradley Ronon Stevens & Young, LLP 2005 Market Street, Suite 2600 Philadelphia, PA 19103 215.564.8000 www.stradley.com |
Jonathan M. Kopcsik
(215) 564-8099
jkopcsik@stradley.com
July 29, 2022
VIA EDGAR
John Grzeskiewicz
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549-9303
| Re: | Ivy Variable Insurance Portfolios (the “Registrant”) | |
File Nos. 033-11466; 811-05017 |
Dear Mr. Grzeskiewicz:
On behalf of the Registrant, below are its responses to the comments you provided us on July 6, 2022 with regard to its Post-Effective Amendment No. 87 (the “Post-Effective Amendment”) to its Registration Statement on Form N-1A relating to certain changes to the Delaware VIP Global Value Equity (formerly, Delaware Ivy VIP Global Equity Income) (the “Fund”). The Post-Effective Amendment was filed with the U.S. Securities and Exchange Commission (“Commission”) on May 27, 2022.
Below we have provided your comments and the Registrant’s responses to them.
| 1. | Comment: Provide completed fee table and expense example numbers for the Fund at least one week prior to the effective date of the Post-Effective Amendment. |
Response: Please Exhibit A for the requested information. | |
| 2. | Comment: Confirm that the Fund’s manager, Delaware Management Company, is not waiving any fees or reimbursing expenses for the Fund. |
Response: The Registrant so confirms. |
* * *
Please direct any questions or comments relating to this filing to me at the above-referenced telephone number.
Very truly yours, /s/Jonathan M. Kopcsik Jonathan M. Kopcsik |
| cc: | Kathryn Williams Macquarie Asset Management |
EXHIBIT A
| Annual portfolio operating expenses (expenses that you pay each year as a percentage of the value of your investment) | |||
Class | II | ||
Management fees | 0.70% | ||
Distribution and service (12b-1) fees | 0.25% | ||
Other expenses | 0.06% | ||
Total annual fund operating expenses | 1.01% | ||
Class | II | ||
1 Year | $103 | ||
3 Years | $322 | ||
5 Years | $558 | ||
10 Years | $1,236 |