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, 2019, 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, 2019.
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.
/s/PricewaterhouseCoopers LLP
New York, New York
February 21, 2020
APPENDIX A
AZL Balanced Index Strategy Fund
AZL DFA Multi-Strategy Fund
AZL MVP Balanced Index Strategy Fund
AZL MVP Global Balanced Index Strategy Fund
AZL MVP DFA Multi-Strategy Fund
AZL MVP Fusion Dynamic Balanced Fund
AZL MVP Fusion Dynamic Conservative Fund
AZL MVP Fusion Dynamic Moderate Fund
AZL MVP Growth Index Strategy Fund
AZL MVP Moderate Index Strategy Fund
AZL MVP Fidelity Institutional Asset Management
Multi-Strategy Fund
AZL MVP T. Rowe Price Capital Appreciation Plus Fund