SecProbe.io

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    Joshua R. Diggs

Counsel

Capital Research and Management Company

333 South Hope Street

Los Angeles, California 90071-1406

(404) 685-4211 Tel

(213) 486-9611 Fax

capitalgroup.com

April 13, 2021

Mark A. Cowan

Senior Counsel

U.S. Securities and Exchange Commission

Division of Investment Management

Disclosure Review Office

100 F Street, N.E.

Washington, D.C. 20549-3628

Re:	American Funds Insurance Series (the
“Registrant” or the “Series”)

File Nos. 002-86838 and 811-03857

Dear Mr. Cowan:

This letter is in response
to the comments you provided on March 16, 2021 to the Registrant’s Post-Effective Amendment No. 96 to the Registration Statement
under the Securities Act of 1933 (the “1933 Act”) and Amendment No. 96 to the Registration Statement under the
Investment Company Act of 1940 (the “1940 Act”), which amendment reflected, among other things, changes to certain
fund names, certain revisions to the funds’ investment strategies and the addition of management fee waivers. We appreciate
your prompt response to the filing.

Our responses to your comments
are set forth below. We will incorporate any changes to the Registration Statement in a subsequent filing pursuant to Rule 485(b)
under the 1933 Act to be automatically effective on May 1, 2021 (the “Amendment”). We understand that, unless
otherwise stated, when a comment is made with respect to disclosure in one portion of the Registration Statement, that comment
is applicable to all similar disclosure appearing elsewhere in the Registration Statement. Accordingly, where applicable, responses
to your comments below with respect to any individual class of shares apply equally to each of the Registrant’s other classes
of shares with similar disclosure.

Cover Page

For each fund that changed its name, please
confirm supplementally that notice was given to fund shareholders as required by Rule 35d-1 under the 1940 Act (“Rule 35d-1”
or the “Names Rule”).

Response: Under Rule 35d-1,
if a fund’s name suggests that the fund focuses its investment in a particular type of investment, or in investments in a
particular industry or group of industries, the fund must adopt a policy to invest, under normal circumstances, at least 80% of
the value of its assets in the particular type of investments, or in investments in the particular industry(ies), suggested by
the fund’s name (an “80% rule”). Such policy must either be a fundamental policy or the fund must provide the
fund’s shareholders with at least 60 days’ prior notice of any change in such
policy. Accordingly, we respectfully disagree with the statement that shareholders must be provided 60 days’ notice
of any change in the fund’s name. Instead, Rule 35d-1 only requires that shareholders receive notice if a fund’s
80% rule is changing (if such 80% rule is not a fundamental policy of the fund).

We hereby confirm that, to the extent
any of the funds that are changing their names have 80% rules in place, such rules will remain unchanged after the effectiveness
of the Amendment. As a result, none of the funds were required to provide prior notice to shareholders.

For example, prior to the effectiveness
of the Amendment, one of Bond Fund’s principal investment strategies is to invest, under normal circumstances, at least 80%
of its assets in bonds and other debt securities. This policy will remain in place after the Amendment becomes effective and the
name of the fund changes to The Bond Fund of America. Because the fund’s 80% rule is not changing, Rule 35d-1 does not require
the fund to provide prior notice to shareholders.

Likewise, although Blue Chip Income
and Growth Fund is changing its name to Washington Mutual Investors Fund, thereby eliminating the reference to “blue chip”
securities in the fund’s name, the fund is retaining its policy to invest “at least 80% of its assets in dividend-paying
common stocks of companies of larger, more established companies domiciled in the United States with market capitalizations greater
than $4.0 billion.” As such, the fund is not required to notify shareholders of the name change.

Summary Prospectus

 A. General

For each fund that changed its name, please
add the former fund name to the header at the beginning of such fund’s summary prospectus.

Response: To the extent applicable,
the section captioned “Principal investment strategies” of each fund’s summary prospectus includes a statement
indicating the former name of the fund. For example, the fourth paragraph of the section captioned “Principal investment
strategies” in Washington Mutual Investors Fund’s summary prospectus states the following: “Prior to May 1, 2021,
the fund was called Blue Chip Income and Growth Fund.” We intentionally placed this statement in the summary prospectus to
make investors aware of the name change in a prominent location in the Registration Statement. We believe this disclosure adequately
notifies investors of any change to the fund’s name. Accordingly, we respectfully decline to supplement the disclosure as
proposed.

.

 B. Washington Mutual Investors Fund

Please supplementally explain the connection
to Washington Mutual in the fund’s name. There is no reference to Washington Mutual in the “Management” section
of the prospectus.

Response: The words “Washington”
and “Mutual,” as they are used in the fund’s name, are not intended to connote any relationship to the company
Washington Mutual. Rather, the fund — which is a variable annuity wrapper of an existing mutual fund and leverages such existing
fund’s strategy — employs the “Washington Mutual Investors Fund” name as a brand name. The existing mutual
fund, which was incepted in 1952, is broadly known by the same name, and we believe there is no risk of investor confusion with
respect to the meaning of the fund’s name.

From 1952 until 2012, the existing
fund operated under a Business Management Agreement with Washington Management Corporation or its predecessors. In 2012, Washington
Management Corporation became a wholly owned subsidiary of Capital Research and Management Company, the fund’s investment
adviser. The existing fund’s historical relationship with Washington Management Corporation was the basis for the existing
fund’s name, and over the past several decades, the existing fund’s name has developed into a broadly known brand.
As a brand name that connotes a clear relationship to the existing mutual fund of the same name, we believe the fund’s “Washington
Mutual Investors Fund” name is neither materially deceptive nor misleading.

In the section captioned “Principal
investment strategies,” please revise the disclosure to specify the types of “other securities” in which the
fund invests in addition to common stock.

Response: One of the fund’s
principal investment strategies, as disclosed in the fund’s summary prospectus, is to invest “primarily in common
stock of established companies that are listed on or meet the financial listing requirements of the New York Stock Exchange and
have a strong record of earnings and dividends.” This disclosure does not mention the “other securities” in
which the fund may invest because it is not a principal strategy of the fund to invest in “other securities” in addition
to common stock.

However, the fund has a separate
principal investment strategy, which is to take current and potential income as well as the potential for long-term capital appreciation
into consideration when selecting common stocks and other securities for investment. This disclosure does not mean that investing
in other securities is a principal investment strategy of the fund; rather, the disclosure simply indicates the factors that the
fund will consider when making investment decisions across all securities in which it invests. It would be misleading to remove
the reference to “other securities” from this sentence because the strategy affects all security types in which the
fund invests.

Consistent with the layered disclosure
approach, we have included a fulsome description of the “other securities” in which the fund may invest in the fund’s
statement of additional information. Specifically, the section captioned “Certain investment limitations and guidelines”
of the fund’s statement of additional information states that “generally, common stocks and securities convertible
into common stocks of issuers on the fund’s Eligible List may be purchased by the fund; however, the fund may also hold,
to a limited extent, short-term U.S. government securities, cash and cash equivalents.” We believe the more detailed description
of the “other securities” in which the fund invests is appropriately placed in the fund’s statement of additional
information because it is not a principal investment strategy of the fund to invest in such instruments.

In the section captioned “Principal
investment strategies,” please revise the disclosure to clarify the nature of the fund’s Investment Standards and how
such standards are reflected in the Eligible List. Please also explain the relationship between the Eligible List and the statement
that “the fund invests primarily in common stocks of established companies that are listed on, or meet the financial listing
requirements of, the New York Stock Exchange and have a strong record of earnings and dividends.” Finally, please clarify
why the Investment Standards and Eligible list are used for this fund.

Response: We have revised the
second paragraph of the section captioned “Principal investment strategies” to address this comment, as set forth below:

The fund has
Investment Standards originally based upon criteria established by the United States District Court for the District of
Columbia for determining
eligibility under the Court’s Legal List procedure, which was in effect for many years. The fund has an
“Eligible List” — based on the Investment Standards —
of investments considered appropriate for a prudent investor seeking opportunities for income and growth of principal consistent
with common stock investing. The investment adviser generates and maintains the Eligible List in
compliance with the fund’s Investment Standards and selects the fund’s investments exclusively from
the issuers on the Eligible List.

In addition, we have revised the section
captioned “Description of certain securities, investment techniques and risks” in the fund’s statement of additional
information to further clarify the factors that the fund will consider when determining which securities to include on the Eligible
List. Such disclosure has been revised as follows:

Washington Mutual Investors Fund has
an Eligible List of investments considered appropriate for a prudent investor seeking opportunities for income and growth of principal
consistent with common stock investing. Numerous criteria govern which securities may be included on the fund’s Eligible
List. Currently, those criteria include, for example: (a) a security shall be listed on the New York Stock Exchange (“NYSE”)
or meet the financial listing requirements of the NYSE (the applicable listing requirements are set forth in Section 1 of the Listed
Company Manual of the NYSE); (b) most companies must have fully earned their dividends in at least four of the past five years
(with the exception of certain banking institutions) and paid a dividend in at least eight of the past ten years; (c) issuing companies
must meet both initial and ongoing market capitalization requirements; (d) the ratio of current assets to liabilities for most
individual companies must be at least 1.5 to 1, or their bonds must be rated at least investment grade by Standard & Poor’s
Ratings Services; and (e) companies must not derive the majority of their revenues from alcohol or tobacco products.

In the section captioned “Principal
investment strategies,” please reconcile the use of the Eligible List with the statement that the “basic investment
philosophy of the investment adviser is to seek to invest in attractively valued securities that, in its opinion, represent good,
long-term investment opportunities.”

Response: Please see our response
to Comment No. 5 above. We believe that the fund’s investments, which are selected exclusively from the Eligible List, are
consistent with the investment philosophy described above.

In the section captioned “Principal
risks,” please consider describing the risks associated with investing in large-capitalization issuers.

Response: We believe that the
fund’s current risk disclosure, including the risks disclosed under the captions “Principal risks — Market conditions”
and “— Issuer risks,” adequately describes the risks associated with investing in large-capitalization issuers.
Accordingly, we believe no further risk disclosure is presently required in response to this comment.

In the section captioned “Investment
results,” please consider deleting the reference to “other applicable measures of market results,” as no such
measures appear in the “Average annual total returns” table.

Response: We have updated the
first sentence of the section captioned “Investment results” to address this comment, as set forth below:

The following bar chart shows how the
investment results of the Class 1 shares of the fund have varied from year to year, and the following table shows how the fund’s
average annual total returns for various periods compare with a broad measure of securities market results and
other applicable measures of market results.

 C. Capital World Growth and Income Fund

We note that the fund includes the word
“World” in its name. In the section entitled “Principal investment strategies,” please clarify that the
fund invests in “a number of countries throughout the world.” See Investment Company Names, Investment Company
Act Release No. 24828, at n. 42 (Jan. 17, 2001). Please also quantify how much of the fund will be invested in non-U.S. issuers.

Response: We have updated the
section captioned “Principal investment strategies” to address this comment, as set forth below:

Under normal market conditions, the
fund will invest a significant portion of its assets in securities of issuers domiciled in a number
of countries outside the United States, including and
such investments may include securities of issuers domiciled in developing countries.

Although Rule 35d-1 is not directly
implicated by the use of the term “world” in the fund’s name, the term “world,” like the terms “international”
and “global,” connotes diversification among investments in a number of different countries throughout the world. Though
not required, the fund’s disclosure, as revised, satisfies the Staff’s stated expectation that an investment company
with the word “global” or “international” in its name will invest its assets in investments that are tied
economically to a number of countries throughout the world (i.e., “… significant exposure to issuers domiciled in at
least three different countries [other than the United States]”). In practice, the fund invests a substantial portion of
its assets in non-U.S. issuers. As of March 31, 2021, approximately 57% of the fund’s assets were invested in securities
of issuers domiciled in 20 countries.

We respectfully decline to assign
a quantitative measure to the term “significant” where the disclosure indicates that the fund will invest a “significant
portion” of its assets in securities of issuers domiciled in a number of countries outside the U.S. The use of the term “significant”
was intentional, as it allows the fund to retain the flexibility to invest in companies domiciled both within and outside the U.S.
over time, depending on market conditions, for the benefit of shareholders. This is consistent with the use of the term “world”
in the fund’s name; as the name implies, the fund will invest in the securities of companies domiciled around the world (i.e.,
both U.S. and non-U.S. issuers), not just in companies domiciled outside the U.S.

In the section cap