SEC Company Response from VANGUARD VARIABLE INSURANCE FUNDS (CIK 0000857490) — Apr 21, 2020
VANGUARD VARIABLE INSURANCE FUNDS (CIK 0000857490)
Date: April 21, 2020 · CIK: 0000857490 · Accession: 0001683863-20-004223
AI Filing Summary & Sentiment
Letter
Washington, DC 20549 RE:Vanguard Variable Insurance Funds (the “Trust”) File No. 33-32216 Post-Effective Amendment No. 93 – Vanguard Diversified Value Portfolio (the “Portfolio”)
Dear Ms. Larkin,
This letter responds to your comments provided on January 31, 2020, to the above referenced post-effective amendment.
Comment 1:
Fund Summary
Comment:
In the “Annual Fund Operating Expenses” section, please confirm that the change to the advisory fee is consistent with the applicable agreements and the terms of the exemptive relief.
Response:
We confirm that the change to the advisory fee is consistent with the applicable agreement(s) and the terms of the exemptive relief.
Comment 2:
Investment Advisors
Comment:
In the “Investment Advisors” section, please add any disclosure required by Item 10(a) Instructions 1, 2, and/or 3 of Form N1-A if applicable.
Response:
We have added the start date for the new advisors, Hotchkis and Wiley Capital Management, LLC and Lazard Asset Management LLC, pursuant to Instruction 1.
Comment 3:
Financial Highlights
Comment:
If the information included in the Financial Highlights is more than 245 days old, unaudited six-month financials must be included with the 485(a) filing.
Response:
The 485(b) filing will include updated Financial Highlights figures.
Please contact me at (610) 669-2531 with any questions or comments regarding the above response. Thank you.
Sincerely,
/s/ Elizabeth Bestoso
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CORRESP 1 filename1.htm P.O. Box 2600 Valley Forge, PA 19482-2600 610-669-2531 Elizabeth_Bestoso@vanguard.com April 21, 2020 Lisa N. Larkin, Esq. U.S. Securities and Exchange Commissionvia electronic filing 100 F Street, N.E. Washington, DC 20549 RE:Vanguard Variable Insurance Funds (the “Trust”) File No. 33-32216 Post-Effective Amendment No. 93 – Vanguard Diversified Value Portfolio (the “Portfolio”) Dear Ms. Larkin, This letter responds to your comments provided on January 31, 2020, to the above referenced post-effective amendment. Comment 1: Fund Summary Comment: In the “Annual Fund Operating Expenses” section, please confirm that the change to the advisory fee is consistent with the applicable agreements and the terms of the exemptive relief. Response: We confirm that the change to the advisory fee is consistent with the applicable agreement(s) and the terms of the exemptive relief. Comment 2: Investment Advisors Comment: In the “Investment Advisors” section, please add any disclosure required by Item 10(a) Instructions 1, 2, and/or 3 of Form N1-A if applicable. Response: We have added the start date for the new advisors, Hotchkis and Wiley Capital Management, LLC and Lazard Asset Management LLC, pursuant to Instruction 1. Comment 3: Financial Highlights Comment: If the information included in the Financial Highlights is more than 245 days old, unaudited six-month financials must be included with the 485(a) filing. Response: The 485(b) filing will include updated Financial Highlights figures. Please contact me at (610) 669-2531 with any questions or comments regarding the above response. Thank you. Sincerely, /s/ Elizabeth Bestoso Elizabeth Bestoso Associate Counsel The Vanguard Group, Inc.