SEC Company Response from STATE STREET VARIABLE INSURANCE SERIES FUNDS INC (CIK 0000746687) — Jun 17, 2020
STATE STREET VARIABLE INSURANCE SERIES FUNDS INC (CIK 0000746687)
Date: June 17, 2020 · CIK: 0000746687 · Accession: 0001193125-20-171321
AI Filing Summary & Sentiment
File numbers found in text: 811-04041
Letter
SEC Response Letter
ROPES & GRAY LLP
PRUDENTIAL TOWER
800 BOYLSTON STREET
BOSTON, MA 02199-3600
WWW.ROPESGRAY.COM
Adam M. Schlichtmann
T +1 617 951 7114
F +1 617 235 7346
adam.schlichtmann@ropesgray.com
June 17, 2020
VIA EDGAR CORRESPONDENCE
Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Re: State Street Variable Insurance Series Funds, Inc. (the “Company”) (Registration Nos. 002-91369 and 811-04041) Certified Shareholder Report on Form N-CSR Filed on February 28, 2020, pursuant to Rule 30b2-1 under the Investment Company Act of 1940, as Amended (the “Shareholder Report”).
Ladies and Gentlemen:
This letter provides the Company’s responses to comments on the above-referenced Shareholder Report of the Company that Ms. Miller provided by telephone to Adam Schlichtmann. For convenience of reference, each of the comments is summarized before the Company’s responses. Capitalized terms not otherwise defined herein have the meanings ascribed to them in the Shareholder Report.
1. Comment: We remind you that the Company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the Staff.
Response: The Company acknowledges the comment.
2. Comment: For State Street Small-Cap Equity V.I.S. Fund, in the notes to the financial statements please state the frequency with which payments are made to the sub-advisers.
Response: The Company will add disclosure on the frequency of payments made to the sub-advisers in the notes to the financial statements in future reports to shareholders.
3. Comment: For State Street Real Estate Securities V.I.S. Fund, please consider adding disclosure in the notes to the financial statements to state that distributions received from REITs may be classified as dividends, capital gains and/or returns of capital.
Response: The Company will add disclosure that distributions received from REITs may be classified as dividends, capital gains and/or returns of capital in future reports to shareholders.
* * *
Please feel free to contact me at 617-951-7114 to discuss any questions or comments you may have regarding the foregoing responses. Thank you for your assistance.
Sincerely,
/s/ Adam M. Schlichtmann
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CORRESP 1 filename1.htm SEC Response Letter ROPES & GRAY LLP PRUDENTIAL TOWER 800 BOYLSTON STREET BOSTON, MA 02199-3600 WWW.ROPESGRAY.COM Adam M. Schlichtmann T +1 617 951 7114 F +1 617 235 7346 adam.schlichtmann@ropesgray.com June 17, 2020 VIA EDGAR CORRESPONDENCE Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, D.C. 20549 Re: State Street Variable Insurance Series Funds, Inc. (the “Company”) (Registration Nos. 002-91369 and 811-04041) Certified Shareholder Report on Form N-CSR Filed on February 28, 2020, pursuant to Rule 30b2-1 under the Investment Company Act of 1940, as Amended (the “Shareholder Report”). Ladies and Gentlemen: This letter provides the Company’s responses to comments on the above-referenced Shareholder Report of the Company that Ms. Miller provided by telephone to Adam Schlichtmann. For convenience of reference, each of the comments is summarized before the Company’s responses. Capitalized terms not otherwise defined herein have the meanings ascribed to them in the Shareholder Report. 1. Comment: We remind you that the Company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the Staff. Response: The Company acknowledges the comment. 2. Comment: For State Street Small-Cap Equity V.I.S. Fund, in the notes to the financial statements please state the frequency with which payments are made to the sub-advisers. Response: The Company will add disclosure on the frequency of payments made to the sub-advisers in the notes to the financial statements in future reports to shareholders. 3. Comment: For State Street Real Estate Securities V.I.S. Fund, please consider adding disclosure in the notes to the financial statements to state that distributions received from REITs may be classified as dividends, capital gains and/or returns of capital. Response: The Company will add disclosure that distributions received from REITs may be classified as dividends, capital gains and/or returns of capital in future reports to shareholders. * * * Please feel free to contact me at 617-951-7114 to discuss any questions or comments you may have regarding the foregoing responses. Thank you for your assistance. Sincerely, /s/ Adam M. Schlichtmann Adam M. Schlichtmann