Correspondence 0000356494-25-000018 from VARIABLE INSURANCE PRODUCTS FUND (CIK 0000356494)
VARIABLE INSURANCE PRODUCTS FUND (CIK 0000356494)
Date: March 31, 2025 · CIK: 0000356494 · Accession: 0000356494-25-000018
AI Filing Summary & Sentiment
File numbers found in text: 811-03329, 811-05361, 811-07205
Letter
Converted by EDGARwiz
COMMENTS RECEIVED ON 03/26/2025
FROM KIM McMANUS
VARIABLE INSURANCE PRODUCTS FUND (File Nos. 002-75010 and 811-03329)
Equity-Income Portfolio
Floating Rate High Income Portfolio
Growth Portfolio
High Income Portfolio
Stock Selector Portfolio
Value Portfolio
POST-EFFECTIVE AMENDMENT NO. 99
VARIABLE INSURANCE PRODUCTS FUND III (File Nos. 033-54837 and 811-07205)
Growth & Income Portfolio
Growth Opportunities Portfolio
Value Strategies Portfolio
POST-EFFECTIVE AMENDMENT NO. 67
VARIABLE INSURANCE PRODUCTS FUND V (File Nos. 033-17704 and 811-05361)
Strategic Income Portfolio
POST-EFFECTIVE AMENDMENT NO. 105
1.
Equity-Income Portfolio
“Fund Summary” (prospectus)
“Principal Investment Strategies”
“Equity securities represent an ownership interest, or the right to acquire an ownership interest, in an issuer. Equity securities include common stocks (including depositary receipts evidencing ownership of common stock), preferred stocks and other preferred securities, convertible securities, rights and warrants, and other securities, such as hybrid securities and trust preferred securities, believed to have equity-like characteristics.”
C:
Since it is stated that equity securities may include convertible debt securities, the Staff requests we confirm our understanding that the fund may include convertible debt securities in its 80% basket of equity securities if the convertible debt is in the money or was in the money when it was purchased. The Staff requests we also confirm that this understanding extends to all Variable Insurance Products and Fidelity Funds.
R:
We confirm that convertible debt securities can be included in the 80% basket for equity securities for all Variable Insurance Products and Fidelity funds if the convertible debt is in the money or was in the money when it was purchased.
Attachment 1
Annual Operating Expenses
(expenses that you pay each year as a % of the value of your investment)
Management fee
0.63%
Distribution and/or Service (12b-1) fees
0.25%
Other expenses
0.04% A
Acquired fund fees and expenses
0.06% B
Total annual operating expenses
0.98% B
ABased on estimated amounts for the current fiscal year.
BIncludes interest expense of certain underlying Fidelity® funds. Excluding interest expense of the applicable underlying Fidelity® funds, total annual operating expenses are 0.92%.
1 year
$
3 years
$
5 years
$
10 years
$
1,201
Show Raw Text
CORRESP 1 filename1.htm Converted by EDGARwiz COMMENTS RECEIVED ON 03/26/2025 FROM KIM McMANUS VARIABLE INSURANCE PRODUCTS FUND (File Nos. 002-75010 and 811-03329) Equity-Income Portfolio Floating Rate High Income Portfolio Growth Portfolio High Income Portfolio Stock Selector Portfolio Value Portfolio POST-EFFECTIVE AMENDMENT NO. 99 VARIABLE INSURANCE PRODUCTS FUND III (File Nos. 033-54837 and 811-07205) Growth & Income Portfolio Growth Opportunities Portfolio Value Strategies Portfolio POST-EFFECTIVE AMENDMENT NO. 67 VARIABLE INSURANCE PRODUCTS FUND V (File Nos. 033-17704 and 811-05361) Strategic Income Portfolio POST-EFFECTIVE AMENDMENT NO. 105 1. Equity-Income Portfolio “Fund Summary” (prospectus) “Principal Investment Strategies” “Equity securities represent an ownership interest, or the right to acquire an ownership interest, in an issuer. Equity securities include common stocks (including depositary receipts evidencing ownership of common stock), preferred stocks and other preferred securities, convertible securities, rights and warrants, and other securities, such as hybrid securities and trust preferred securities, believed to have equity-like characteristics.” C: Since it is stated that equity securities may include convertible debt securities, the Staff requests we confirm our understanding that the fund may include convertible debt securities in its 80% basket of equity securities if the convertible debt is in the money or was in the money when it was purchased. The Staff requests we also confirm that this understanding extends to all Variable Insurance Products and Fidelity Funds. R: We confirm that convertible debt securities can be included in the 80% basket for equity securities for all Variable Insurance Products and Fidelity funds if the convertible debt is in the money or was in the money when it was purchased. Attachment 1 Annual Operating Expenses (expenses that you pay each year as a % of the value of your investment) Management fee 0.63% Distribution and/or Service (12b-1) fees 0.25% Other expenses 0.04% A Acquired fund fees and expenses 0.06% B Total annual operating expenses 0.98% B ABased on estimated amounts for the current fiscal year. BIncludes interest expense of certain underlying Fidelity® funds. Excluding interest expense of the applicable underlying Fidelity® funds, total annual operating expenses are 0.92%. 1 year $ 100 3 years $ 312 5 years $ 542 10 years $ 1,201