Correspondence 0000088053-23-000158 from DEUTSCHE DWS VARIABLE SERIES II (CIK 0000810573)
DEUTSCHE DWS VARIABLE SERIES II (CIK 0000810573)
Date: April 6, 2023 · CIK: 0000810573 · Accession: 0000088053-23-000158
AI Filing Summary & Sentiment
File numbers found in text: 811-05002
Letter
VIA EDGAR United States Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, D.C. 20549 Attn: Rebecca Marquigny Re: Post-Effective Amendment No. 124 to the Registration Statement on Form N-1A of DWS Global Income Builder VIP (“Fund”), a series of Deutsche DWS Variable Series II (“Registrant”) (Reg. Nos. 33-11802/ 811-05002)
Dear Ms. Marquigny,
This letter is being submitted on behalf of the Fund in response to comments of the Staff of the Securities and Exchange Commission (the “SEC”) on the above-referenced Post-Effective Amendment (the “Amendment”), which comments were received via telephone on March 29, 2023. The Amendment was filed on behalf of the Fund on February 15, 2023 and has an effective date of May 1, 2023.
The Staff’s comment is restated below followed by the Registrant’s/Fund’s response.
1. Comment: Most of the ELN disclosure appears consistent with prior Staff comments on the ELN disclosure in DWS Global Income Builder Fund (the corresponding retail fund in Deutsche DWS Market Trust). However, there are several exceptions in which the Amendment does not include language that conforms to the Staff’s prior comments. Please reconcile the nonconforming disclosure. If the language will not be conformed to the retail fund (1) supplementally identify and explain the exceptions or (2) affirmatively represent that any inconsistencies are not material and would have been appropriate if submitted via a 485(b) filing.
Response: The Fund has confirmed that the Fund’s disclosure conforms to the disclosure in the corresponding retail fund, reflecting the prior comments of the Staff.
If you have any questions regarding any of the foregoing or require additional information, please call me at (617) 295-3681.
Sincerely yours,
/s/ Laura McCollum
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DWS Investment Management Americas, Inc.
100 Summer Street
Boston, MA 02110
April 6, 2023
VIA EDGAR
United States Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Attn: Rebecca Marquigny
Re:
Post-Effective Amendment No. 124 to the Registration Statement on Form N-1A of DWS Global Income Builder VIP (“Fund”), a series of Deutsche DWS Variable Series II (“Registrant”) (Reg. Nos. 33-11802/ 811-05002)
Dear Ms. Marquigny,
This letter is being submitted on behalf of
the Fund in response to comments of the Staff of the Securities and Exchange Commission (the “SEC”) on the above-referenced
Post-Effective Amendment (the “Amendment”), which comments were received via telephone on March 29, 2023. The Amendment was
filed on behalf of the Fund on February 15, 2023 and has an effective date of May 1, 2023.
The Staff’s comment is restated below
followed by the Registrant’s/Fund’s response.
1. Comment: Most of the ELN disclosure appears consistent with prior Staff comments on the ELN disclosure
in DWS Global Income Builder Fund (the corresponding retail fund in Deutsche DWS Market Trust). However, there are several exceptions
in which the Amendment does not include language that conforms to the Staff’s prior comments. Please reconcile the nonconforming
disclosure. If the language will not be conformed to the retail fund (1) supplementally identify and explain the exceptions or (2) affirmatively
represent that any inconsistencies are not material and would have been appropriate if submitted via a 485(b) filing.
Response: The Fund has confirmed
that the Fund’s disclosure conforms to the disclosure in the corresponding retail fund, reflecting the prior comments of the Staff.
If you have any questions regarding any of the
foregoing or require additional information, please call me at (617) 295-3681.
Sincerely yours,
/s/ Laura McCollum
Laura McCollum
Senior Legal Counsel
DWS
Investment Management Americas, Inc.
John Marten, Vedder Price PC