Report of Independent Registered Public Accounting Firm
To the Board of Trustees of and Shareholders of Allianz Variable
Insurance Products Fund of Funds Trust
In planning and performing our audits of the financial
statements of each of the funds constituting Allianz Variable
Insurance Products Fund of Funds Trust (as listed in Appendix
A and hereafter referred to collectively as 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 fund'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 fund'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 fund; (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 fund are being made only in accordance
with authorizations of management and trustees of the fund;
and (3) provide reasonable assurance regarding prevention
or timely detection of unauthorized acquisition, use or
disposition of a fund'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 Funds' 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 their operation, including controls
over safeguarding securities, that we consider to be material
weaknesses as defined above as of December 31, 2018.
PricewaterhouseCoopers LLP, PricewaterhouseCoopers Center,
300 Madison Avenue, New York, NY 10017 T: (646) 471 3000,
F: (813) 286 6000, www.pwc.com/us
This report is intended solely for the information and use of
the Board of Trustees of Allianz Variable Insurance Products
Fund of Funds Trust and the Securities and Exchange Commission
and is not intended to be and should not be used by anyone
other than these specified parties.
PricewaterhouseCoopers LLP
New York, New York
February 22, 2019
Appendix A
AZL DFA Multi-Strategy Fund
AZL Balanced Index Strategy Fund
AZL MVP DFA Multi-Strategy fund
AZL MVP Balanced Index Strategy Fund
AZL MVP Moderate Index Strategy Fund
AZL MVP Growth Index Strategy Fund
AZL MVP Fusion Dynamic Moderate Fund
AZL MVP Fusion Dynamic Balanced Fund
AZL MVP Fusion Dynamic Conservative Fund
AZL MVP FIAM Multi-Strategy Fund
AZL MVP T. Rowe Price Capital Appreciation Plus Fund