[Van Eck Global Letterhead]
May 22, 2006
VIA EDGAR
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: Patricia Williams
RE: Van Eck Worldwide Insurance Trust
File Nos. 033-13019 and 811-05083
485(a) Registration Statement and Subsequent 485(b) Filing
Ladies and Gentlemen,
This letter is being submitted on the Registrant's behalf in response to
the comments of the Staff of the Division of Investment Management (the "Staff")
provided by Michael Kosoff to Heidi Cain in a telephone conversation on April
17, 2006, regarding the Registration Statement on Form N-1A of Van Eck Worldwide
Insurance Trust (the "Registrant"), an open-end management investment company
registered under the Investment Company Act of 1940 (the "1940 Act"), as
amended, and the Securities Act of 1933 (the "1933 Act"), as amended, relating
to the Registrant's filing under Rule 485(a) under the 1933 Act on March 1,
2005. The Registrant filed with the Commission a Post-Effective Amendment
pursuant to Rule 485(b) under the 1933 Act on April 28, 2006. The documents
filed reflect the changes discussed herein.
The Registrant is comprised of five separate portfolio series: Worldwide
Bond Fund, Worldwide Emerging Markets Fund, Worldwide Hard Assets Fund and
Worldwide Real Estate Fund, offered in one prospectus, and Worldwide Absolute
Return Fund, offered in a separate prospectus (each, a "Fund", and together, the
"Funds"). Each Fund offers three classes of shares in separate prospectuses:
Initial Class, Class R1 and S Class shares.
The Staff's comments are set forth below together with the Registrant's
responses thereto.
GENERAL: ALL PROSPECTUSES
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COMMENT NO. 1: On the back cover of the Prospectuses, the telephone number
stated for the Securities and Exchange Commission's Public Reference Room is
incorrect. Please correct this.
Response: The Registrant has made the requested change.
COMMENT NO. 2: In the paragraph preceding the Expense Example for all of
the Funds, please indicate that the expenses listed in the table do not reflect
charges at the separate account level, and if they did, the expenses would be
higher than those shown.
Response: The Registrant has made the requested change.
COMMENT NO. 3: In the section describing the Portfolio Managers, provide
more detailed information as to each Portfolio Manager's business experience
during the past five years.
Response: The Registrant has made the requested change.
COMMENT NO. 4: In the Additional Investment Strategies section, for the
Asset Backed Securities and CMOs risk disclosures, please include in the "risk"
paragraph language stating that the assets backing the security can lose value,
making the investment less secured.
Response: The Registrant has made the requested change.
COMMENT NO. 5: In the Additional Investment Strategies section, under
Foreign Securities, make reference to the SAI tax section and state that there
may be varying tax consequences.
Response: The Registrant has made the requested change.
COMMENT NO. 6: Explain either in the prospectus itself or in the response
letter why the Frequent Trading section is included in the Additional Investment
Strategies section. If the Frequent Trading section is not necessary, please
remove this disclosure from the prospectuses.
Response: The Registrant has removed the Frequent Trading risk disclosure
from the prospectuses for all the Funds.
COMMENT NO. 7: In the Additional Investment Strategies section, add a
"definition" paragraph to the Market Risk and Market Timing sections.
Response: The Registrant has made the requested change.
GENERAL: ALL STATEMENTS OF ADDITIONAL INFORMATION
- -------------------------------------------------
COMMENT NO. 8: In the Taxes section, please state that foreign taxes may be
imposed on investments in foreign securities regardless of any tax deferred
status granted by the Internal Revenue Code with respect to these investments.
Response: The Registrant has made the requested change.
COMMENT NO. 9: In the response letter, confirm that the Trustees whose
principal occupations in the past 5 years are "private investors" had no other
employment during the last 5 years.
Response: Registrant confirms that the Trustees whose occupations for the
past five years are listed as "private investors" had no other employment during
that period.
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WORLDWIDE INSURANCE TRUST: INITIAL CLASS PROSPECTUS
- ---------------------------------------------------
COMMENT NO. 10: In the Principal Risk sections for Worldwide Emerging
Markets Fund and Worldwide Real Estate Fund, please include additional language
indicating that these Funds are subject to the risks associated with junk bonds.
Response: The Registrant has made the requested change.
WORLDWIDE ABSOLUTE RETURN FUND: PROSPECTUS
- ------------------------------------------
COMMENT NO. 11: In the Principal Risks section, please add language
indicating that the Fund is subject to the risks associated with short sales.
Response: The Registrant has made the requested change.
COMMENT NO. 12: Make certain that the Total Fund Operating Expenses number
stated in the footnote to the Shareholder Expenses table is updated.
Response: The Registrant has made the requested change.
WORLDWIDE ABSOLUTE RETURN FUND: STATEMENT OF ADDITIONAL INFORMATION
- -------------------------------------------------------------------
COMMENT NO. 13: Make certain that the document refers to "Fund" in the
singular rather than to "Funds" in the plural.
Response: The Registrant has examined the document and made the changes
where necessary and appropriate.
COMMENT NO. 14: In the section entitled Portfolio Manager Compensation,
please reference the actual index used as performance benchmark in determining
the compensation for Analytic's Portfolio Managers.
Response: Based on information provided to the Registrant by Analytic, the
Registrant has revised the disclosure to reflect the compensation system
currently utilized by Analytic. The revised disclosure reads as follows:
"For Analytic, the compensation structure for professional employees consists of
an industry median base salary (based on independent industry information) and
an annual discretionary bonus. Bonus amounts are determined using the following
factors: the overall success of the firm; the overall success of the department
or team; and an individual's contribution to the team. Members of Analytic's
senior management team and investment management professionals may also have a
deferred component to their total compensation (with a three-year vesting
period) that is invested in the firm's investment products to tie the interests
of the individual to the interests of the firm and our clients. Portfolio
managers' base salaries are typically reviewed on an annual basis determined by
each portfolio manager's date of employment. Discretionary bonuses are
determined annually, upon analysis of information from the prior calendar year."
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* * *
At the request of the Staff, the undersigned acknowledges on behalf of the
Registrant that:
o the Registrant is responsible for the adequacy and accuracy of the
disclosure in the Prospectuses and Statements of Additional
Information for the series' of the Van Eck Worldwide Insurance Trust;
o the Staff's comments and the changes to the Van Eck Worldwide
Insurance Trust's Prospectuses and Statements of Additional
Information made by the Registrant in response to the Staff's comments
do not foreclose the SEC from taking any action with respect to the
Prospectuses and Statements of Additional Information; and
o the Registrant may not assert the Staff's comments as a defense in any
proceeding initiated by the SEC or any person under the federal
securities laws of the United States.
* * *
If you have any questions with respect to the foregoing, please do not hesitate
to telephone me at 212-293-2031.
Sincerely,
/s/ Joseph J. McBrien
Joseph J. McBrien
Senior Vice President and Secretary
Cc: Michael Kosoff
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