SEC Company Response from NATIONWIDE VARIABLE INSURANCE TRUST (CIK 0000353905) — Nov 8, 2005
NATIONWIDE VARIABLE INSURANCE TRUST (CIK 0000353905)
Date: Nov. 8, 2005 · CIK: 0000353905 · Accession: 0001137439-05-000266
AI Filing Summary & Sentiment
File numbers found in text: 811-03213
Letter
Via EDGAR Correspondence November 8, 2005 Mr. Tony Burak U.S. Securities and Exchange Commission Division of Investment Management Office of Insurance Products Stop Office 05-06 100 F Street, N.E. Washington, D. C. 20549-0506 (202) 551-6750 burakt@sec.gov
Subject: Comments to Gartmore Variable Insurance Trust's Annual Form N-CSR for the Fiscal Year Ended December 31, 2004
Dear Mr. Burak:
On Thursday, October 6, 2005, we received comments from you, via telephone, regarding the Form N-CSR filed by Gartmore Variable Insurance Trust ("GVIT") for GVIT's fiscal year ended December 31, 2004 (hereinafter, the "Comments"). GVIT is an open-end management investment company consisting of multiple series (hereinafter, the "Funds" or the "GVIT Funds") that are managed by either Gartmore Mutual Fund Capital Trust or Gartmore Global Asset Management Trust (collectively, "Gartmore" or the "Advisers," unless noted otherwise). With respect to some of the Funds, the Advisers supervise subadvisers who manage these Funds on a day-to-day basis.
You have requested in your October 6, 2005 Comments that the Comments be applied on a going-forward basis, as appropriate, and that written responses be filed via EDGAR correspondence within approximately thirty (30) days. This letter is intended to respond to the Comments on behalf of GVIT and makes reference to certain sections of and pages in the GVIT December 31, 2004 annual report as filed on Form N-CSR (hereinafter, the "Annual Report") via EDGAR with the U.S. Securities and Exchange Commission (the "Commission") on March 11, 2005.
To assist you in your review of our responses to the Comments, we have included each Comment immediately before our response to that Comment.
Mr. Tony Burak November 8, 2005 Page 2 of 11
1. Cover Page: 1940 Act File Number: The number provided for GVIT's Investment Company Act File Number (i.e., 002-73024) is GVIT's Securities Act of 1933 File Number. Please provide the correct GVIT Investment Company Act File Number.
Response: We will provide GVIT's correct Investment Company Act File Number (i.e., 811-03213) going forward.
2. Item I: Statement Regarding Availability of Quarterly Portfolio Schedule: This statement represents that the GVIT Funds' Forms N-Q are available on Gartmore's website, however the Commission staff was not able to locate the GVIT Funds' Forms N-Q on Gartmore's website. Please confirm that the GVIT Funds' Forms N-Q are available on Gartmore's website or, if not yet available, advise when these Forms N-Q will be available on Gartmore's website.
Response: The information on Forms N-Q for GVIT is now (and going forward will continue to be made) available to GVIT shareholders on www.gartmorefunds.com and also will continue to be made available upon request without charge).
3. Item I: Fund Performance & Shareholder Expense Example -- All GVIT Funds: Variable insurance contracts impose sales charges and other charges and expenses on variable insurance contract holders. These sales charges and other charges and expenses are described in variable insurance contract prospectuses, as opposed to in the prospectuses for the underlying funds in which these insurance contracts invest. Industry best practice is to disclose in annual and semi-annual reports to fund shareholders under both the "Performance" discussion and the "Shareholder Expense Example" that the respective performance and expense calculations do not include charges that will be imposed by variable insurance contracts that have invested in the funds. Please confirm that, going forward, Gartmore will include this disclosure in GVIT annual and semi-annual reports, as appropriate, or, if not, explain why Gartmore does not intend to include this disclosure in these reports.
Response: At the request of the Commission, Gartmore, going forward, will follow industry practice and include in GVIT's annual and semi-annual reports on Form N-CSR, under "Fund Performance" and the "Shareholder Expense Example," the disclosure that the respective performance and expense calculations for the GVIT Funds do not include charges that will be imposed by variable insurance contracts that have invested in the GVIT Funds.
Mr. Tony Burak November 8, 2005 Page 3 of 11
4. Item I: Statements of Investments: Securities Lending: For each of the following seventeen GVIT Funds, please identify, under "Short-Term Securities Held As Collateral For Securities Lending," the actual securities on loan by the GVIT Fund as of the date of the Annual Report. See, e.g., Regulation S-X, at Article 4-08(b); FASB No. 140, at Paragraphs 12 and 15; and AICPA Audit & Accounting Guidelines, at Paragraphs 2.64 and 7.27.
Gartmore GVIT Nationwide Fund Gartmore GVIT Growth Fund Gartmore GVIT Government Bond Fund Gartmore GVIT Mid Cap Growth Fund Comstock GVIT Value Fund Federated GVIT High Income Bond Fund GVIT Equity 500 Index Fund Van Kampen GVIT Multi Sector Bond Fund GVIT Small Cap Growth Fund Gartmore GVIT Worldwide Leaders Fund Dreyfus GVIT Mid Cap Index Fund Gartmore GVIT Global Technology and Communications Fund Gartmore GVIT Global Health Sciences Fund Gartmore GVIT Emerging Markets Fund Dreyfus GVIT International Value Fund Gartmore GVIT U.S. Growth Leaders Fund Gartmore GVIT Developing Markets Fund
Going forward, we will designate the actual securities on loan by the GVIT Funds at the date of the Annual Report with footnote disclosure in the Statements of Investments (i.e., that a portion or all of the shares of the security currently are on loan).
5. Item I: Statements of Investments: Restricted Securities -- Money Market Funds: For each of the two GVIT Money Market Funds, please identify any and all "Restricted Securities" held by the GVIT Fund as of the date of the Annual Report. See Regulation S-X, at Article 12-12.6 (which sets forth the details required to be disclosed).
Response: Restricted securities are disclosed in the Annual Report under the "Statement of Investments" for these two GVIT Money Market Funds. Please refer to footnote (b) at page 151 of the Annual Report under the "Statement of Investments" for the Gartmore GVIT Money Market Fund, and to footnote (b) at page 153 of the Annual Report under the "Statement of Investments" for the Gartmore GVIT Money Market Fund II, each of which footnotes identifies
Mr. Tony Burak November 8, 2005 Page 4 of 11
those "Restricted Securities" held by each of the respective GVIT Money Market Funds as of December 31, 2004.
As the Commission Staff is aware, registered investment companies are subject to limitations on their investments in illiquid securities. An illiquid security is any security which may not be sold or disposed of in the ordinary course of business within seven (7) days at approximately the value at which the investment company has valued the investment. As set forth in the Guidelines to Form N-1A, a registered open-end investment company (i.e., a "mutual fund" or "fund") may invest no more than fifteen percent (15%) of the fund's assets in illiquid securities; except that a money market fund may invest no more than ten percent (10%) of the fund's assets in illiquid securities. See, e.g., Investment Company Act Release No. 18612 (March 12, 1992); Investment Company Act Release No. 14983 (March 12, 1986). See also, e.g., Guide 4, "Types of Securities," to Registration Statement on Form N-1A; Letter To Paul Schott Stevens, Investment Company Institute, from Jack Murphy, SEC Division of Investment Management (May 26, 1995).
Please note that, as applicable to registered investment companies and their advisers, the Commission Staff, in a no-action letter from the Staff, has deemed certain commercial paper issued in reliance on the exemption from registration in Section 4(2) of the Securities Act of 1933, as amended (the "1933 Act") (said commercial paper hereinafter referred to as "Section 4(2) commercial paper"), and held by an investment company, to be liquid if: (i) the Section 4(2) commercial paper is not traded flat or is not in default as to principal or to interest; (ii) the Section 4(2) commercial paper is rated in one of the two highest rating categories by at least two nationally-recognized statistical rating organizations; and (iii) the adviser (pursuant to authority delegated by the board) considers the trading market for the specific security, taking into account all relevant factors. An investment company's adviser may conditionally determine for purposes of the 85% liquidity requirements (90% liquidity requirements for money market funds) that an issue of Section 4(2) commercial paper is liquid, whether or not this paper may be resold under Rule 144A, if certain conditions are met. See Merrill Lynch Money Markets, Inc. (SEC Reference No. 93-684-CC, File No. 132-3, dated January 14, 1994).
The "Restricted Securities" held by the Gartmore GVIT Money Market Funds: (i) are certain commercial paper issued in reliance on the exemption from registration in Section 4(2) of the 1933 Act (i.e., Section 4(2) commercial paper), and, as indicated in footnote (b) under the "Statements of Investments," were deemed to be "liquid" securities pursuant to procedures approved by the GVIT Board of Trustees (i.e.. the GVIT Board's Guidelines For the Determination of the Liquidity of Certain Securities). The "Restricted Securities" held by the Gartmore GVIT Money Market Funds,
Mr. Tony Burak November 8, 2005 Page 5 of 11
however, are not "Rule 144A" Restricted Securities (i.e., securities eligible for resale under Rule 144A of the 1933 Act).
6. Item I: Statements of Investments: Warrants: For each of the following three GVIT Funds, please identify any and all "Warrants" held by the GVIT Fund as of the date of the Annual Report, and note, as appropriate that these "Warrants" are "non-income producing securities."
Federated GVIT High Income Bond Fund Van Kampen GVIT Multi Sector Bond Fund GVIT Small Cap Value Fund
Response: We agree with this comment, and, going forward, we will identify any and all "Warrants" as non-income producing securities. Accordingly, for example, we would designate any and all "Warrants" as non-income producing securities under the "Statement of Investments" with:
i. footnote (h) at page 178 of the Annual Report for the Federated GVIT High Income Bond Fund;
ii. footnote (b) at page 199 of the Annual Report for the Van Kampen GVIT Multi Sector Bond Fund; and
iii. footnote (b) at page 210 of the Annual Report for the GVIT Small Cap Value Fund.
7. Item I: Statements of Investments: Participation Notes -- Gartmore GVIT Developing Markets Fund: For the Gartmore GVIT Developing Markets Fund, please disclose, under "Participation Notes," the interest rate payable in regard to the following three fixed-income securities held by this GVIT Fund.
Larsen & Toubro Ltd (due January 19, 2009) Oil & Natural Gas Corp., Ltd (due October 31, 2005) ITC Ltd (due April 7, 2030)
Response: These three securities disclosed under the heading "Participation Notes" in the Statement of Investments for the Gartmore GVIT Developing Markets Fund, at page 250 of the Annual Report -- as well as under the heading "Participation Notes" in the Statement of Investments for the Gartmore GVIT Emerging Markets Fund, at page 229 of the Annual Report -- are not "fixed-income securities," but rather are synthetic instruments linked to equity securities (i.e., "equity-linked notes"). An equity-linked note is a security that combines the characteristics of a zero- or low-coupon bond or
Mr. Tony Burak November 8, 2005 Page 6 of 11
note with a return component based on the performance of a single-equity security, a basket of equity securities, or an equity index. No interest rate is payable in regard to any of these three equity-linked securities held by either of these GVIT Funds, and, accordingly, going forward, Gartmore will indicate, as appropriate, that the interest rate is zero in regard to these securities when disclosed under the heading "Participation Notes" in the Statement of Investments.
8. Item I: Statements of Assets & Liabilities: Transactions In Options Contracts Written -- J.P. Morgan GVIT Balanced Fund:
a. In regard to the transactions in options contracts written by the J.P. Morgan GVIT Balanced Fund, please disclose, as of the date of the Annual Report (i.e., as of the period ended December 31, 2004): (i) the balance of the open contract -- as a separate line item; and (ii) the value of the premiums received from these options contracts written.
Response: The balance of these options contracts written by the J.P. Morgan GVIT Balanced Fund (the only GVIT Fund that writes these contracts) inadvertently were included in the balances reported under the subheading "Payable for variation margin on futures and options contracts" under the heading "Liabilities" in the Statement of Assets & Liabilities at page 252 for this GVIT Fund. Going forward, the GVIT Funds will disclose these balances under the separate subheading "Call Options Written, at fair value $X (premiums received $Y)," under the heading "Liabilities" in the Statements of Assets & Liabilities.
b. At page 312, in Footnote 2(g), "Summary of Significant Accounting Policies; Written Options Contracts," the premium received balance for the J.P. Morgan GVIT Balanced Fund should agree with the open options contracts written by this GVIT Fund. Please reconcile these balances and include the appropriate chart in the footnote.
Response: Please note that the chart reconciling these balances in regard to transactions in options contracts written by the J.P. Morgan GVIT Balanced Fund is presented in this GVIT Fund's Statement of Investments, at page 163 of the Annual Report, in accordance with the AICPA Audit & Accounting Guidelines, at Paragraph 7.84. Currently, the J.P. Morgan GVIT Balanced Fund is the only GVIT Fund that writes options contracts.
Mr. Tony Burak November 8, 2005 Page 7 of 11
9. Item I: Statements o
Show Raw Text
CORRESP
1
filename1.htm
GVIT SEC Correspondence as filed November 8, 2005
[GARTMORE LOGO]
Via EDGAR Correspondence
November 8, 2005
Mr. Tony Burak
U.S. Securities and Exchange Commission
Division of Investment Management
Office of Insurance Products
Stop Office 05-06
100 F Street, N.E.
Washington, D. C. 20549-0506
(202) 551-6750
burakt@sec.gov
Subject: Comments to Gartmore Variable Insurance Trust's Annual
Form N-CSR for the Fiscal Year Ended December 31, 2004
Dear Mr. Burak:
On Thursday, October 6, 2005, we received comments from you, via telephone,
regarding the Form N-CSR filed by Gartmore Variable Insurance Trust ("GVIT") for
GVIT's fiscal year ended December 31, 2004 (hereinafter, the "Comments"). GVIT
is an open-end management investment company consisting of multiple series
(hereinafter, the "Funds" or the "GVIT Funds") that are managed by either
Gartmore Mutual Fund Capital Trust or Gartmore Global Asset Management Trust
(collectively, "Gartmore" or the "Advisers," unless noted otherwise). With
respect to some of the Funds, the Advisers supervise subadvisers who manage
these Funds on a day-to-day basis.
You have requested in your October 6, 2005 Comments that the Comments be
applied on a going-forward basis, as appropriate, and that written responses be
filed via EDGAR correspondence within approximately thirty (30) days. This
letter is intended to respond to the Comments on behalf of GVIT and makes
reference to certain sections of and pages in the GVIT December 31, 2004 annual
report as filed on Form N-CSR (hereinafter, the "Annual Report") via EDGAR with
the U.S. Securities and Exchange Commission (the "Commission") on March 11,
2005.
To assist you in your review of our responses to the Comments, we have
included each Comment immediately before our response to that Comment.
Mr. Tony Burak
November 8, 2005
Page 2 of 11
1. Cover Page: 1940 Act File Number: The number provided for GVIT's Investment
Company Act File Number (i.e., 002-73024) is GVIT's Securities Act of 1933
File Number. Please provide the correct GVIT Investment Company Act File
Number.
Response: We will provide GVIT's correct Investment Company Act File Number
(i.e., 811-03213) going forward.
2. Item I: Statement Regarding Availability of Quarterly Portfolio Schedule:
This statement represents that the GVIT Funds' Forms N-Q are available on
Gartmore's website, however the Commission staff was not able to locate the
GVIT Funds' Forms N-Q on Gartmore's website. Please confirm that the GVIT
Funds' Forms N-Q are available on Gartmore's website or, if not yet
available, advise when these Forms N-Q will be available on Gartmore's
website.
Response: The information on Forms N-Q for GVIT is now (and going forward
will continue to be made) available to GVIT shareholders on
www.gartmorefunds.com and also will continue to be made available upon
request without charge).
3. Item I: Fund Performance & Shareholder Expense Example -- All GVIT Funds:
Variable insurance contracts impose sales charges and other charges and
expenses on variable insurance contract holders. These sales charges and
other charges and expenses are described in variable insurance contract
prospectuses, as opposed to in the prospectuses for the underlying funds in
which these insurance contracts invest. Industry best practice is to
disclose in annual and semi-annual reports to fund shareholders under both
the "Performance" discussion and the "Shareholder Expense Example" that the
respective performance and expense calculations do not include charges that
will be imposed by variable insurance contracts that have invested in the
funds. Please confirm that, going forward, Gartmore will include this
disclosure in GVIT annual and semi-annual reports, as appropriate, or, if
not, explain why Gartmore does not intend to include this disclosure in
these reports.
Response: At the request of the Commission, Gartmore, going forward, will
follow industry practice and include in GVIT's annual and semi-annual
reports on Form N-CSR, under "Fund Performance" and the "Shareholder
Expense Example," the disclosure that the respective performance and
expense calculations for the GVIT Funds do not include charges that will be
imposed by variable insurance contracts that have invested in the GVIT
Funds.
Mr. Tony Burak
November 8, 2005
Page 3 of 11
4. Item I: Statements of Investments: Securities Lending: For each of the
following seventeen GVIT Funds, please identify, under "Short-Term
Securities Held As Collateral For Securities Lending," the actual
securities on loan by the GVIT Fund as of the date of the Annual Report.
See, e.g., Regulation S-X, at Article 4-08(b); FASB No. 140, at Paragraphs
12 and 15; and AICPA Audit & Accounting Guidelines, at Paragraphs 2.64 and
7.27.
Gartmore GVIT Nationwide Fund
Gartmore GVIT Growth Fund
Gartmore GVIT Government Bond Fund
Gartmore GVIT Mid Cap Growth Fund
Comstock GVIT Value Fund
Federated GVIT High Income Bond Fund
GVIT Equity 500 Index Fund
Van Kampen GVIT Multi Sector Bond Fund
GVIT Small Cap Growth Fund
Gartmore GVIT Worldwide Leaders Fund
Dreyfus GVIT Mid Cap Index Fund
Gartmore GVIT Global Technology and Communications Fund
Gartmore GVIT Global Health Sciences Fund
Gartmore GVIT Emerging Markets Fund
Dreyfus GVIT International Value Fund
Gartmore GVIT U.S. Growth Leaders Fund
Gartmore GVIT Developing Markets Fund
Going forward, we will designate the actual securities on loan by the GVIT
Funds at the date of the Annual Report with footnote disclosure in the
Statements of Investments (i.e., that a portion or all of the shares of the
security currently are on loan).
5. Item I: Statements of Investments: Restricted Securities -- Money Market
Funds: For each of the two GVIT Money Market Funds, please identify any and
all "Restricted Securities" held by the GVIT Fund as of the date of the
Annual Report. See Regulation S-X, at Article 12-12.6 (which sets forth the
details required to be disclosed).
Response: Restricted securities are disclosed in the Annual Report under
the "Statement of Investments" for these two GVIT Money Market Funds.
Please refer to footnote (b) at page 151 of the Annual Report under the
"Statement of Investments" for the Gartmore GVIT Money Market Fund, and to
footnote (b) at page 153 of the Annual Report under the "Statement of
Investments" for the Gartmore GVIT Money Market Fund II, each of which
footnotes identifies
Mr. Tony Burak
November 8, 2005
Page 4 of 11
those "Restricted Securities" held by each of the respective GVIT Money
Market Funds as of December 31, 2004.
As the Commission Staff is aware, registered investment companies are
subject to limitations on their investments in illiquid securities. An
illiquid security is any security which may not be sold or disposed of in
the ordinary course of business within seven (7) days at approximately the
value at which the investment company has valued the investment. As set
forth in the Guidelines to Form N-1A, a registered open-end investment
company (i.e., a "mutual fund" or "fund") may invest no more than fifteen
percent (15%) of the fund's assets in illiquid securities; except that a
money market fund may invest no more than ten percent (10%) of the fund's
assets in illiquid securities. See, e.g., Investment Company Act Release
No. 18612 (March 12, 1992); Investment Company Act Release No. 14983 (March
12, 1986). See also, e.g., Guide 4, "Types of Securities," to Registration
Statement on Form N-1A; Letter To Paul Schott Stevens, Investment Company
Institute, from Jack Murphy, SEC Division of Investment Management (May 26,
1995).
Please note that, as applicable to registered investment companies and
their advisers, the Commission Staff, in a no-action letter from the Staff,
has deemed certain commercial paper issued in reliance on the exemption
from registration in Section 4(2) of the Securities Act of 1933, as amended
(the "1933 Act") (said commercial paper hereinafter referred to as "Section
4(2) commercial paper"), and held by an investment company, to be liquid
if: (i) the Section 4(2) commercial paper is not traded flat or is not in
default as to principal or to interest; (ii) the Section 4(2) commercial
paper is rated in one of the two highest rating categories by at least two
nationally-recognized statistical rating organizations; and (iii) the
adviser (pursuant to authority delegated by the board) considers the
trading market for the specific security, taking into account all relevant
factors. An investment company's adviser may conditionally determine for
purposes of the 85% liquidity requirements (90% liquidity requirements for
money market funds) that an issue of Section 4(2) commercial paper is
liquid, whether or not this paper may be resold under Rule 144A, if certain
conditions are met. See Merrill Lynch Money Markets, Inc. (SEC Reference
No. 93-684-CC, File No. 132-3, dated January 14, 1994).
The "Restricted Securities" held by the Gartmore GVIT Money Market Funds:
(i) are certain commercial paper issued in reliance on the exemption from
registration in Section 4(2) of the 1933 Act (i.e., Section 4(2) commercial
paper), and, as indicated in footnote (b) under the "Statements of
Investments," were deemed to be "liquid" securities pursuant to procedures
approved by the GVIT Board of Trustees (i.e.. the GVIT Board's Guidelines
For the Determination of the Liquidity of Certain Securities). The
"Restricted Securities" held by the Gartmore GVIT Money Market Funds,
Mr. Tony Burak
November 8, 2005
Page 5 of 11
however, are not "Rule 144A" Restricted Securities (i.e., securities
eligible for resale under Rule 144A of the 1933 Act).
6. Item I: Statements of Investments: Warrants: For each of the following
three GVIT Funds, please identify any and all "Warrants" held by the GVIT
Fund as of the date of the Annual Report, and note, as appropriate that
these "Warrants" are "non-income producing securities."
Federated GVIT High Income Bond Fund
Van Kampen GVIT Multi Sector Bond Fund
GVIT Small Cap Value Fund
Response: We agree with this comment, and, going forward, we will identify
any and all "Warrants" as non-income producing securities. Accordingly, for
example, we would designate any and all "Warrants" as non-income producing
securities under the "Statement of Investments" with:
i. footnote (h) at page 178 of the Annual Report for the Federated
GVIT High Income Bond Fund;
ii. footnote (b) at page 199 of the Annual Report for the Van Kampen
GVIT Multi Sector Bond Fund; and
iii. footnote (b) at page 210 of the Annual Report for the GVIT Small
Cap Value Fund.
7. Item I: Statements of Investments: Participation Notes -- Gartmore GVIT
Developing Markets Fund: For the Gartmore GVIT Developing Markets Fund,
please disclose, under "Participation Notes," the interest rate payable in
regard to the following three fixed-income securities held by this GVIT
Fund.
Larsen & Toubro Ltd (due January 19, 2009)
Oil & Natural Gas Corp., Ltd (due October 31, 2005)
ITC Ltd (due April 7, 2030)
Response: These three securities disclosed under the heading "Participation
Notes" in the Statement of Investments for the Gartmore GVIT Developing
Markets Fund, at page 250 of the Annual Report -- as well as under the
heading "Participation Notes" in the Statement of Investments for the
Gartmore GVIT Emerging Markets Fund, at page 229 of the Annual Report --
are not "fixed-income securities," but rather are synthetic instruments
linked to equity securities (i.e., "equity-linked notes"). An equity-linked
note is a security that combines the characteristics of a zero- or
low-coupon bond or
Mr. Tony Burak
November 8, 2005
Page 6 of 11
note with a return component based on the performance of a single-equity
security, a basket of equity securities, or an equity index. No interest
rate is payable in regard to any of these three equity-linked securities
held by either of these GVIT Funds, and, accordingly, going forward,
Gartmore will indicate, as appropriate, that the interest rate is zero in
regard to these securities when disclosed under the heading "Participation
Notes" in the Statement of Investments.
8. Item I: Statements of Assets & Liabilities: Transactions In Options
Contracts Written -- J.P. Morgan GVIT Balanced Fund:
a. In regard to the transactions in options contracts written by the J.P.
Morgan GVIT Balanced Fund, please disclose, as of the date of the Annual
Report (i.e., as of the period ended December 31, 2004): (i) the balance of
the open contract -- as a separate line item; and (ii) the value of the
premiums received from these options contracts written.
Response: The balance of these options contracts written by the J.P. Morgan
GVIT Balanced Fund (the only GVIT Fund that writes these contracts)
inadvertently were included in the balances reported under the subheading
"Payable for variation margin on futures and options contracts" under the
heading "Liabilities" in the Statement of Assets & Liabilities at page 252
for this GVIT Fund. Going forward, the GVIT Funds will disclose these
balances under the separate subheading "Call Options Written, at fair value
$X (premiums received $Y)," under the heading "Liabilities" in the
Statements of Assets & Liabilities.
b. At page 312, in Footnote 2(g), "Summary of Significant Accounting Policies;
Written Options Contracts," the premium received balance for the J.P.
Morgan GVIT Balanced Fund should agree with the open options contracts
written by this GVIT Fund. Please reconcile these balances and include the
appropriate chart in the footnote.
Response: Please note that the chart reconciling these balances in regard
to transactions in options contracts written by the J.P. Morgan GVIT
Balanced Fund is presented in this GVIT Fund's Statement of Investments, at
page 163 of the Annual Report, in accordance with the AICPA Audit &
Accounting Guidelines, at Paragraph 7.84. Currently, the J.P. Morgan GVIT
Balanced Fund is the only GVIT Fund that writes options contracts.
Mr. Tony Burak
November 8, 2005
Page 7 of 11
9. Item I: Statements o