SecProbe.io

CORRESP
1
filename1.htm

    Joshua R. Diggs

    Counsel

    Capital Research and Management Company

    333 South Hope Street

    Los Angeles, California 90071-1406

    (213) 615-0047 Tel

    (213) 486-9611 Fax

    capitalgroup.com

November 30, 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 October 22, 2021 to the Registrant’s Post-Effective Amendment No. 98 to the Registration Statement under
the Securities Act of 1933 (the “1933 Act”) and Amendment No. 98 to the Registration Statement under the Investment
Company Act of 1940 (the “1940 Act”), which amendment reflected, among other things, certain revisions to the fund’s
investment strategies and the addition of a management fee waiver. 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 immediately effective on December 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.

Summary Prospectus

 A. International Growth and Income Fund

In the section captioned “Fees and expenses
of the fund,” please confirm supplementally if the fund pays any other fees, such as brokerage commission and other fees to financial
intermediaries, and if so, please revise the disclosure accordingly.

Response: We have considered the Registrant’s
disclosure in light of the Staff’s comment and we believe the Registrant’s current disclosure is sufficient. The disclosure
notes that the fund “may pay other fees, such as insurance contract fees and expenses, which are not reflected in the tables and
examples below.” Because the fund is not sold directly to the general public but instead is offered as an underlying investment
option for variable insurance contracts, the fund and its related companies may make payments to the sponsoring insurance company (or
its affiliates) for distribution and/or other services. We hereby confirm supplementally that the fund pays insurance contract fees and
expenses, and we believe the Registrant’s current disclosure is sufficient.

In the section captioned “Principal investment
strategies,” please confirm supplementally if cash and cash equivalents (including shares of money market or similar funds managed
by the investment adviser or its affiliates) and securities held as collateral issued by U.S. issuers are included in the 90% minimum
test for the fund’s assets, and if so, please revise the disclosure accordingly.

Response: We hereby confirm supplementally
that cash and cash equivalents (including shares of money market or similar funds managed by the investment adviser or its affiliates)
and securities held as collateral issued by U.S. issuers are included in the 90% minimum test for the fund’s assets. We have updated
the disclosure to address this comment as set forth below.

The fund currently intends to invest at least 90% of its assets
in securities of issuers domiciled outside the United States and whose securities
are listed primarily on exchanges outside the United States, and
in cash, and cash
equivalents (including shares of money market or similar funds managed by the investment adviser or its affiliates) and securities held
as collateral issued by U.S. issuers.

In the section captioned “Principal investment
strategies,” please confirm supplementally whether the fund has any investment criteria related to capitalization, and if so, please
consider including appropriate risk disclosure.

Response: We hereby confirm supplementally
that the fund does not have any investment criteria related to capitalization. As such, we respectfully decline to include risk disclosure
regarding capitalization in the section captioned “Principal risks.”

In the section captioned “Principal risks,”
please describe the risks associated with Brexit and investing in China, if applicable.

Response: International Growth and
Income Fund is actively managed and relies on the professional judgement of its investment adviser to make decisions about the fund’s
portfolio investments. It is not an investment strategy of the fund to invest in securities of issuers in any particular market. As such,
we disclose risks associated with investing outside of the United States, including in emerging markets. Accordingly, at this time, we
respectfully decline to specifically disclose Brexit risks associated with investing in the United Kingdom and risks associated with investing
in China. However, we note supplementally that, because the investment portfolio of the fund is actively managed, and because, from time
to time, the fund may have significant exposure to a particular country, region, industry or sector, the fund’s prospectus includes
disclosure regarding the risk of such exposure.

In the section captioned “Principal risks,”
please consider addressing risks related to market manipulation concerns and limited reliable access to capital in emerging markets. See
ADI 2020-11.

Response: With respect to market manipulation
concerns, we believe the Registrant’s current disclosure is sufficient. The disclosure notes that “emerging market countries
tend to have less developed political, economic and legal systems and accounting and auditing practices and standards than those in developed
countries” and “[a]ccordingly, the governments of these countries may be less stable and more likely to intervene in the market
economy.” The disclosure also notes that the “[s]ecurities markets in these countries can also be relatively small and have
substantially lower trading volumes” and “[a]s a result, securities issued in these countries may be more volatile and less
liquid.” We believe the Registrant’s current disclosure is sufficient to inform investors of the risk that stock prices in
emerging markets may be more susceptible to manipulation due to less developed systems, practices and standards and fewer circulating
shares as compared to those in developed countries. With respect to limited reliable access to capital in emerging markets, we have updated
the disclosure in the section captioned “Principal risks” as set forth below:

In addition, the economies of these countries may be dependent
on relatively few industries, may have limited reliable access to capital and may be more susceptible
to changes in local and global trade conditions and downturns in the world economy.

Please confirm supplementally whether International
Growth and Income Fund invests or intends to invest in contingent convertible securities, either as a principal investment strategy or
as an additional strategy.  If International Growth and Income Fund invests in contingent convertible securities, please state supplementally
the amount the fund currently invests in such securities.

Response: International Growth and
Income Fund may invest in contingent convertible securities as a non-principal investment strategy; however, as of the date hereof, International
Growth and Income Fund has no investments in contingent convertible securities. Nevertheless, the Registrant has included disclosure regarding
contingent convertible securities and the risks thereof in its statement of additional information under “Description of certain
securities, investment techniques and risks – Hybrid securities.”

Please confirm supplementally whether International
Growth and Income Fund invests or intends to invest in preferred stocks, contingent preferred stocks and convertible bonds as a principal
investment strategy, and if so, please consider including appropriate risk disclosure.

Response: We have updated the disclosure
to address this comment as set forth below.

Investing in growth-oriented stocks
— Growth-oriented common stocks and other equity-type securities (such as preferred stocks,
convertible preferred stocks and convertible bonds) may involve larger price swings and greater potential for loss
than other types of investments. These risks may be even greater in the case of smaller capitalization stocks.

In the section captioned “Management,”
please revise the disclosure to clarify that the individual portfolio managers are jointly and primarily responsible for the portfolio
management of the fund.

Response: We respectfully decline
to revise the disclosure to clarify that the individual portfolio managers are jointly and primarily responsible for the portfolio management
of the fund. We note that Item 5(b) of Form N-1A requires disclosure only of those persons “who are primarily responsible
for the day-to-day management of the Fund’s portfolio (‘Portfolio Manager’)” [emphasis added]. In accordance with
this requirement, the disclosure states which individual portfolio managers are primarily responsible for the portfolio management of
the fund. Further, we do not view the disclosed portfolio managers as being “jointly responsible” for the portfolio management
of the fund. As disclosed in the Registration Statement, under The Capital SystemSM, the Registrant’s investment adviser
uses a system of multiple portfolio managers in managing mutual fund assets. Under this approach, the portfolio of a fund is divided into
segments managed by individual managers, and portfolio managers are individually responsible for management of their respective segments.

Statutory Prospectus

In the section captioned “Investment objectives,
strategies and risks,” please confirm supplementally if cash and cash equivalents (including shares of money market or similar funds
managed by the investment adviser or its affiliates) and securities held as collateral issued by U.S. issuers are included in the 90%
minimum test for the fund’s assets, and if so, please revise the disclosure accordingly.

Response: Please see our response
to Comment No. 2 above.

In the section captioned “Investment objectives,
strategies and risks,” International Growth and Income Fund states that it “may also invest in securities of issuers domiciled
outside the United States in the form of depositary receipts or other instruments by which the fund may obtain exposure to equity
investments in local markets” [emphasis added].  Please disclose what these other instruments are.

Response: We hereby confirm supplementally
that “or other instruments” refers to a broad range of asset types, including in particular, participation notes and market
access warrants.  These instruments are not expected to be a principal investment strategy of the fund, but because the fund may
hold them from time to time, the risks relating to participation notes, market access warrants and other similar instruments are disclosed
in the Registrant’s statement of additional information.  We believe the current disclosure is consistent with the Staff’s
guidance on layered disclosure and that no further change is required in response to this comment.

In the section captioned “Investment objectives,
strategies and risks,” please disclose the effect of investing a substantial portion of the fund’s assets in cash or cash
equivalents for temporary defensive purposes.

Response: We have considered the Registrant’s
disclosure in light of the Staff’s comment and we believe the Registrant’s current disclosure is sufficient. In particular,
the paragraph beginning “The fund may also hold cash or cash equivalents . . .” in the section captioned “Investment
objectives, strategies and risks” includes the following sentences in response to Instruction 6 to Item 9(b) of Form N-1A, which
requires that the prospectus disclose the effect of taking any temporary defensive position: “A larger percentage of such holdings
could moderate the fund’s investment results in a period of rising market prices. Alternatively, a larger percentage of such holdings
could reduce the magnitude of the fund’s loss in a period of falling market prices and provide liquidity to make additional investments
or to meet redemptions.” We believe this disclosure is appropriately responsive to the requirements of Form N-1A, and, accordingly,
we respectfully decline to supplement the disclosure as proposed.

The prospectus indicates that the fund may invest
in the Central Funds. If acquired fund fees and expenses (“AFFE”) from such investments will exceed 0.01% of the average net
assets of the fund, please disclose these fees and expenses as a separate line item in the fee table.  Otherwise, please confirm
supplementally that such expenses, if any, are reflected in “Other Expenses.”  [Instr. 3(f) to Item 3.]

Response: We hereby confirm supplementally
that, if AFFE exceed 0.01% of the average net assets of the fund, the fund will include a separate line item in the fee table for AFFE.
The fund's AFFE is not expected to exceed 0.01% of the average net assets of the fund at this time, and as a result, any such expenses
will be reflected in "Other Expenses."

The prospectus indicates that the fund may invest
in the Central Funds. Please include additional disclosure regarding any risks related to expenses or results as a result of investments
in other investment companies managed by the investment adviser or its affiliates.

Response: We have considered the Registrant’s
disclosure in light of the Staff’s comment. Because it is not a principal investment strategy of the fund to invest in Central Funds,
we respectfully decline to include additional disclosure in the Registrant’s summary prospectus regarding any risks related to expenses
or results as a result of investments in other investment companies managed by the investment adviser or its affiliates. However, consistent
with the Staff’s guidance on layered disclosure, we have updated the disclosure in the Registrant’s statement of additional
information under “Affiliated investment companies” to include the additional disclosure regarding any risks related to expenses
as set forth below.

Affiliated investment companies — Certain
funds may purchase shares of another investment company managed by the investment adviser or its affiliates. The risks of owning another
investment company are similar to the risks of investing directly in the securities in which that investment company invests. When
investing in another investment company, the fund bears its proportionate share of the expenses of any investment company in which it
invests but does not bear additional management fees through its investment in such investment company. Investments in other
investment companies could allow a fund to obtain the benefits of a more diversified portfolio than might otherwise be available through
direct investments in a particular asset class, and will subject the fund to the risks associated with the particular asset class or asset
classes in which an underlying fund invests. However, an investment company may not achieve its investment objective or execute its investment
strategy effectively, which may adversely affect the fund’s performance. Any investment in another investment company will be consistent
with the fund’s objective(s) and applicable regulatory limitations.

With respect to any risks related to results,
the current disclosure states that “[t]he risks of owning another investment company are similar to the risks of investing directly
in the securities in whic