September 11, 2017
VIA EDGAR
Mr. Trace Rakestraw
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street NE
Washington, DC 20549-4720
| Re: | American Century Variable Portfolios, Inc. (the “Registrant”) (File Nos. 033-14567; 811-05188) |
Dear Mr. Rakestraw:
Please find below our response to your comment that we discussed on August 16, 2017, regarding Post-Effective Amendment No. 71 to the Registrant’s registration statement filed on July 5, 2017 for the purpose of adding Class Y shares to the VP Capital Appreciation Fund (the “Fund”). For your convenience, we restate your comment prior to our response.
| 1. | Comment: Is the fee waiver subject to recoupment? |
Response: No.
| 2. | Comment: Confirm that the fee waiver cannot be changed. |
Response: The fee waiver cannot be changed without the prior approval of the Board of Directors.
3. Comment: Consider deleting the second sentence in the Fund Performance section.
Response: The comment has been incorporated.
If you have any questions with regard to the above responses, please contact Giles Walsh at giles_walsh@americancentury.com or 816-340-3390.
| American Century Investments | |
| P.O. Box 410141, 4500 Main Street | 1-800-345-2021 or 816-531-5575 |
| Kansas City, MO 64141-0141 | www.americancentury.com |
Mr. Trace Rakestraw
September 11, 2017
Page 2
| Sincerely, | |
| /s/ Giles Walsh | |
| Giles Walsh | |
| Corporate Counsel | |