Correspondence 0001137439-23-000552 from Ivy Variable Insurance Portfolios (CIK 0000810016)
Ivy Variable Insurance Portfolios (CIK 0000810016)
Date: April 28, 2023 · CIK: 0000810016 · Accession: 0001137439-23-000552
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 811-05017
Letter
VIA EDGAR Division of Investment Management Washington, D.C. 20549-9303 Re: Ivy Variable Insurance Portfolios (the “Registrant”) File Nos. 033-11466; 811-05017
Dear Ms. Brutlag:
On behalf of the Registrant, below is its response to the comment you provided to us on April 12, 2023 with regard to its Post-Effective Amendment No. 91 (the “Post-Effective Amendment”) to its Registration Statement on Form N-1A relating to certain changes to the Delaware Ivy VIP Natural Resources (the “Fund”). The Post-Effective Amendment was filed with the U.S. Securities and Exchange Commission (“Commission”) on February 27, 2023.
Below we have provided your comment and the Registrant’s responses to it.
1.
Comment: Provide a completed fee table and expense example for the Fund.
Response: Please see the attached Exhibit A.
* *
Please direct any questions or comments relating to this filing to me at the above-referenced telephone number.
Very truly yours,
/s/Jonathan M. Kopcsik
Show Raw Text
CORRESP
1
filename1.htm
Stradley Ronon Stevens & Young, LLP
2005 Market Street, Suite 2600
Philadelphia, PA 19103
215.564.8000
www.stradley.com
Jonathan M. Kopcsik
(215) 564-8099
jkopcsik@stradley.com
April 28, 2023
VIA EDGAR
Samantha A. Brutlag
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549-9303
Re:
Ivy Variable Insurance Portfolios (the “Registrant”)
File Nos. 033-11466; 811-05017
Dear Ms. Brutlag:
On behalf of the Registrant, below is its response to the comment you provided to us on April 12, 2023 with regard to
its Post-Effective Amendment No. 91 (the “Post-Effective Amendment”) to its Registration Statement on Form N-1A relating to certain changes to the Delaware Ivy VIP Natural Resources (the “Fund”). The Post-Effective Amendment was filed with the U.S.
Securities and Exchange Commission (“Commission”) on February 27, 2023.
Below we have provided your comment and the Registrant’s responses to it.
1.
Comment: Provide a completed fee table and expense example
for the Fund.
Response: Please see the attached Exhibit A.
* *
Please direct any questions or comments relating to this filing to me at the above-referenced telephone number.
Very truly yours,
/s/Jonathan M. Kopcsik
Jonathan M. Kopcsik
cc:
Phil Shipp
Macquarie Asset Management
EXHIBIT A
What are the Portfolio’s fees and expenses?
The following table describes the fees and expenses that you may pay if you buy, hold, and sell shares of the Portfolio. The fee table and example do not
reflect any fees or sales charges imposed by variable insurance contracts. If they did, the expenses would be higher.
Annual portfolio operating expenses (expenses that you pay each year as a percentage of the value of your investment)
Class II
Management fees
0.85%
Distribution and service (12b-1) fees
0.25%
Other expenses
0.15%
Total annual portfolio operating expenses
1.25%
Example
This example is intended to help you compare the cost of investing in the Portfolio with the cost of investing in other mutual funds. The example assumes that
you invest $10,000 in the Portfolio for the time periods indicated and then redeem all of your shares at the end of those periods. The example also assumes that your investment has a 5% return each year. Although your actual costs may be higher or
lower, based on these assumptions your costs would be:
Class II
1 year
$127
3 years
$397
5 years
$686
10 years
$1,511