ERIK NELSON, SR. SECURITIES COUNSEL
Allianz Investment Management LLC
5701 Golden Hills Drive | Minneapolis Minnesota | 55416-1297
Telephone: 763-765-7453
Fax: 763-765-6355
August 14, 2009
Sally Samuel, Senior Counsel
Securities and Exchange Commission
Division of Investment Management
Office of Insurance Products
100 F Street NE
Washington, DC 20549
RE: Allianz Variable Insurance Products Trust (the "VIP Trust")
Pre-Effective Amendment No. 1
File No. 333-160351
and
Allianz Variable Insurance Products Fund of Funds Trust (the "FOF
Trust")
Pre-Effective Amendment No. 1
File No. 333-160352
Dear Ms. Samuel:
On August 6, 2009, we received additional comments telephonically from you and
Tony Burak regarding the above-referenced filings, submitted June 30, 2009,
amended August 3, 2009, in connection with the reorganization of nineteen funds
of the VIP Trust and two funds of the FOF Trust. This letter supplements my
prior response to comments, dated August 11, 2009.
At your request, I enclose the pages reflecting changes made to the Schedules of
Portfolio Investments for the mergers into S&P 500 Index Fund and into Balanced
and Moderate Index Strategy Funds in response to the following comment.
ACCOUNTING COMMENT: Reference is made to comment #32 in my letter of
August 3, 2009, responding to comments. Comment #32 applies to the
mergers into the S&P 500 Index Fund and into the Balanced and Moderate
Index Strategy Funds. Show appropriate adjustments in the Pro Forma
Combined Schedules of Portfolio Investments to show the sale of all
assets or substantial portions of the assets of the acquired funds.
1
The Registrants acknowledge that the Registrants are responsible for the
adequacy and accuracy of the disclosure in the filing. Staff comments on the
filing and changes to the filing following staff comments do not foreclose the
Commission from taking an action with respect to the filing and does not relieve
the Registrants from their full responsibility for the adequacy and accuracy of
the disclosure in the filing. The Registrants understand that they cannot raise
the fact that the staff reviewed the filing as a defense in any proceeding
initiated by the Commission or any person under the federal securities laws of
the United States.
Sincerely,
/s/ Erik Nelson
Allianz Variable Insurance Products Trust
Allianz Variable Insurance Products Fund of Funds Trust
5701 Golden Hills Drive
Minneapolis, Minnesota 55416-1297
August 13, 2009
VIA EDGAR
Sally Samuel
Securities and Exchange Commission
Division of Investment Management
Office of Insurance Products
100 F Street
Washington, DC 20549
Re: Allianz Variable Insurance Products Trust and
Allianz Variable Insurance Products Fund of Funds Trust (the
"Registrants")
Registration Statements on Form N-14 (File Nos. 333-160351 and 333-160352)
Request for Acceleration of Effectiveness
Ms. Samuel:
In accordance with Rule 461 under the Securities Act of 1933, the above
referenced Registrants hereby request that the effective date of Pre-Effective
Amendment No. 1 to the Registration Statements referenced above be accelerated
to become effective on August 17, 2009, or as soon thereafter as practicable.
The Registrants acknowledge that the disclosure in the filing is the
responsibility of the Registrants. The Registrants acknowledge that changes to
the Registration Statement based on staff comments do not bar the Commission
from taking future action and that should the Commission or the staff of the
Commission, acting pursuant to delegated authority, declare the filing
effective, it does not foreclose the Commission from taking any action with
respect to the filing. The Registrants represents that they will not assert this
declaration as a defense in any proceeding initiated by the commission or by any
person under the federal securities of the United States. The Registrants
further acknowledge that the action of the Commission or the staff of the
Commission, acting pursuant to delegated authority, in declaring the filing
effective does not relieve the Registrants from their full responsibility for
the adequacy and accuracy of the disclosures in the filing.
Sincerely,
ALLIANZ VARIABLE INSURANCE PRODUCTS TRUST
ALLIANZ VARIABLE INSURANCE PRODUCTS FUND OF
FUNDS TRUST
By: /s/ Brian Muench
______________________________________
Brian Muench, Vice President
Allianz Life Financial Services, LLC
5701 Golden Hills Drive
Minneapolis, Minnesota 55416-1297
August 13, 2009
VIA EDGAR
Sally Samuel
Securities and Exchange Commission
Division of Investment Management
Office of Insurance Products
100 F Street
Washington, DC 20549
Re: Allianz Variable Insurance Products Trust and
Allianz Variable Insurance Products Fund of Funds Trust (the
"Registrants")
Registration Statements on Form N-14 (File Nos. 333-160351 and 333-160352)
Request for Acceleration of Effectiveness
Ms. Samuel:
Allianz Life Financial Services, LLC, the distributor for the Allianz
Variable Insurance Products Trust and the Allianz Variable Insurance Products
Fund of Funds Trust, pursuant to Rule 461 under the Securities Act of 1933, as
amended, hereby requests that the effective date of Pre-Effective Amendment No.
1 to the Trust's Registration Statements on Form N-14 (File Nos. 333-160351 and
333-160352) be accelerated to become effective on August 17, 2009 or as soon
thereafter as practicable.
The Registrants acknowledge that the disclosure in the filing is the
responsibility of the Registrants. The Registrants acknowledge that changes to
the Registration Statement based on staff comments do not bar the Commission
from taking future action and that should the Commission or the staff of the
Commission, acting pursuant to delegated authority, declare the filing
effective, it does not foreclose the Commission from taking any action with
respect to the filing. The Registrants represents that they will not assert this
declaration as a defense in any proceeding initiated by the commission or by any
person under the federal securities of the United States. The Registrants
further acknowledge that the action of the Commission or the staff of the
Commission, acting pursuant to delegated authority, in declaring the filing
effective does not relieve the Registrants from their full responsibility for
the adequacy and accuracy of the disclosures in the filing.
ALLIANZ LIFE FINANCIAL SERVICES, LLC
By: /s/ Stewart Gregg
___________________________________
Stewart Gregg, Vice President