Correspondence 0000880195-25-000019 from VARIABLE INSURANCE PRODUCTS FUND IV (CIK 0000720318)
VARIABLE INSURANCE PRODUCTS FUND IV (CIK 0000720318)
Date: April 8, 2025 · CIK: 0000720318 · Accession: 0000880195-25-000019
AI Filing Summary & Sentiment
File numbers found in text: 811-03759
Letter
Converted by EDGARwiz
COMMENTS RECEIVED ON 04/04/2025
FROM DANIEL GREENSPAN
VARIABLE INSURANCE PRODUCTS FUND IV (File Nos. 002-84130 and 811-03759)
Communication Services Portfolio, Industrials Portfolio, Materials Portfolio, Utilities Portfolio
POST-EFFECTIVE AMENDMENT NO. 132
1)
“Fund Summary” (prospectus)
“Fee Table”
C:
The Staff requests we explain in correspondence the reason for including the estimated footnote
since this filing is for a new class rather than a new fund.
R:
Although each fund is not a “New Fund” as defined in Instruction 6 of Item 3 of Form N-1A, the
“Management fee” and “Other expenses” line items of the fee table include certain fees and
expenses that are expected to be incurred in different amounts by this class as compared to
other classes of each fund. Therefore, we believe it is appropriate to note that these fees and
expenses are based on estimated amounts for the current fiscal year because this class has
not begun incurring these fees and expenses.
2)
“Fund Summary” (prospectus)
“Performance”
C:
The Staff requests we identify each fund's appropriate broad-based securities market
index.
R:
Each fund’s appropriate broad-based securities market index is the S&P 500 Index. The index description appears in the “Additional Index Information” section of the prospectus.
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CORRESP 1 filename1.htm Converted by EDGARwiz COMMENTS RECEIVED ON 04/04/2025 FROM DANIEL GREENSPAN VARIABLE INSURANCE PRODUCTS FUND IV (File Nos. 002-84130 and 811-03759) Communication Services Portfolio, Industrials Portfolio, Materials Portfolio, Utilities Portfolio POST-EFFECTIVE AMENDMENT NO. 132 1) “Fund Summary” (prospectus) “Fee Table” C: The Staff requests we explain in correspondence the reason for including the estimated footnote since this filing is for a new class rather than a new fund. R: Although each fund is not a “New Fund” as defined in Instruction 6 of Item 3 of Form N-1A, the “Management fee” and “Other expenses” line items of the fee table include certain fees and expenses that are expected to be incurred in different amounts by this class as compared to other classes of each fund. Therefore, we believe it is appropriate to note that these fees and expenses are based on estimated amounts for the current fiscal year because this class has not begun incurring these fees and expenses. 2) “Fund Summary” (prospectus) “Performance” C: The Staff requests we identify each fund's appropriate broad-based securities market index. R: Each fund’s appropriate broad-based securities market index is the S&P 500 Index. The index description appears in the “Additional Index Information” section of the prospectus.