Report of Independent Registered Public
Accounting Firm
To the Board of Trustees of Schwab Annuity Portfolios
and Shareholders of Schwab VIT Balanced Portfolio,
Schwab VIT Balanced with Growth Portfolio, Schwab
VIT Growth Portfolio, Schwab Government Money
Market Portfolio and Schwab S&P500 Index Portfolio
(hereafter collectively referred to as the "Funds")
In planning and performing our audit of the financial
statements of the Funds as of and for the year ended
December 31, 2018, in accordance with the standards of
the Public Company Accounting Oversight Board
(United States) ("PCAOB"), we considered the Funds'
internal control over financial reporting, including
controls over safeguarding securities, as a basis for
designing our auditing procedures for the purpose of
expressing our opinion on the financial statements and
to comply with the requirements of Form N-CEN, but
not for the purpose of expressing an opinion on the
effectiveness of the Funds' internal control over financial
reporting. Accordingly, we do not express an opinion on
the effectiveness of the Funds' internal control over
financial reporting.
The management of the Funds is responsible for
establishing and maintaining effective internal control
over financial reporting. In fulfilling this responsibility,
estimates and judgments by management are required to
assess the expected benefits and related costs of controls.
A company's internal control over financial reporting is a
process designed to provide reasonable assurance
regarding the reliability of financial reporting and the
preparation of financial statements for external purposes
in accordance with generally accepted accounting
principles. A company's internal control over financial
reporting includes those policies and procedures that (1)
pertain to the maintenance of records that, in reasonable
detail, accurately and fairly reflect the transactions and
dispositions of the assets of the company; (2) provide
reasonable assurance that transactions are recorded as
necessary to permit preparation of financial statements
in accordance with generally accepted accounting
principles, and that receipts and expenditures of the
company are being made only in accordance with
authorizations of management and directors of the
company; and (3) provide reasonable assurance
regarding prevention or timely detection of unauthorized
acquisition, use or disposition of a company's assets that
could have a material effect on the financial statements.
Because of its inherent limitations, internal control over
financial reporting may not prevent or detect
misstatements. Also, projections of any evaluation of
effectiveness to future periods are subject to the risk that
controls may become inadequate because of changes in
conditions, or that the degree of compliance with the
policies or procedures may deteriorate.
A deficiency in internal control over financial reporting
exists when the design or operation of a control does not
allow management or employees, in the normal course of
performing their assigned functions, to prevent or detect
misstatements on a timely basis. A material weakness is
a deficiency, or a combination of deficiencies, in internal
control over financial reporting, such that there is a
reasonable possibility that a material misstatement of
the company's annual or interim financial statements
will not be prevented or detected on a timely basis.
Our consideration of the Funds' internal control over
financial reporting was for the limited purpose described
in the first paragraph and would not necessarily disclose
all deficiencies in internal control over financial
reporting that might be material weaknesses under
standards established by the PCAOB. However, we noted
no deficiencies in the Funds' internal control over
financial reporting and its operation, including controls
over safeguarding securities, that we consider to be a
material weakness as defined above as of December 31,
2018.
This report is intended solely for the information and use
of the Board of Trustees of Schwab Annuity Portfolios
and the Securities and Exchange Commission and is not
intended to be and should not be used by anyone other
than these specified parties.

/s/ PricewaterhouseCoopers LLP
San Francisco, California
February 19, 2019