Correspondence 0001683863-23-003801 from VANGUARD VARIABLE INSURANCE FUNDS (CIK 0000857490)
VANGUARD VARIABLE INSURANCE FUNDS (CIK 0000857490)
Date: April 27, 2023 · CIK: 0000857490 · Accession: 0001683863-23-003801
AI Filing Summary & Sentiment
Letter
Washington, DC 20549 Re: Vanguard Variable Insurance Funds (the "Trust") File No. 033-32216 Post-Effective Amendment No. 101 – Vanguard High Yield Bond Portfolio
Dear Ms. Larkin:
This letter responds to your comments provided on March 31, 2023, on the above-referenced post-effective amendment. The comments apply to Vanguard High Yield Bond Portfolio, a series of the Trust.
Prospectus Comments
Comment 1: On page 11, in the section "Security Selection," in the second sentence of the third paragraph, consider using a plain English version of "high-yield sector leads."
Response: We have revised the description and replaced "high-yield sector leads" with "Vanguard's high-yield team."
Comment 2: On page 11, in the section "Security Selection," in the third paragraph, consider whether "Fixed Income Group" should be a defined term.
Response: We have reviewed the disclosure, which notes that the Fixed Income Group is a group within Vanguard. It is not a defined term, but it is Vanguard's standard manner of referring to the investment team within Vanguard whose focus is fixed income investments.
Comment 3: On page 12, in the section "Security Selection," in the ninth paragraph, please indicate whether the references to "advisor" should be to "advisors" since the fund has more than one advisor.
Response: We have deleted the paragraph because each advisor's security selection process is described elsewhere in the prospectus.
P.O. Box 2600
Valley Forge, PA 19482 michael_drayo@vanguard.com
Statement of Additional Information Comments
Comment 4: Please update all financial information as of the most recent fiscal year end where appropriate.
Response: We have updated all financial information as of the most recent fiscal year end where appropriate.
Comment 5: On page B"83, include a reference to "High Yield Bond Portfolio" in the list of portfolios; a portion of the assets of which are advised by Vanguard.
Response: We have revised the disclosure accordingly.
If you have any questions, please contact me at michael_drayo@vanguard.com.
Sincerely,
/s/ Michael Drayo
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SEC Comment Response Letter for VVIF High Yield Bond Portfolio
P.O. Box 2600
Valley Forge, PA 19482 michael_drayo@vanguard.com
April 27, 2023
Lisa N. Larkin, Esq.
via electronic filing
U.S. Securities & Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: Vanguard Variable Insurance Funds (the "Trust")
File No. 033-32216
Post-Effective Amendment No. 101 – Vanguard High Yield Bond Portfolio
Dear Ms. Larkin:
This letter responds to your comments provided on March 31, 2023, on the above-referenced post-effective amendment. The comments apply to Vanguard High Yield Bond Portfolio, a series of the Trust.
Prospectus Comments
Comment 1: On page 11, in the section "Security Selection," in the second sentence of the third paragraph, consider using a plain English version of "high-yield sector leads."
Response: We have revised the description and replaced "high-yield sector leads" with "Vanguard's high-yield team."
Comment 2: On page 11, in the section "Security Selection," in the third paragraph, consider whether "Fixed Income Group" should be a defined term.
Response: We have reviewed the disclosure, which notes that the Fixed Income Group is a group within Vanguard. It is not a defined term, but it is Vanguard's standard manner of referring to the investment team within Vanguard whose focus is fixed income investments.
Comment 3: On page 12, in the section "Security Selection," in the ninth paragraph, please indicate whether the references to "advisor" should be to "advisors" since the fund has more than one advisor.
Response: We have deleted the paragraph because each advisor's security selection process is described elsewhere in the prospectus.
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P.O. Box 2600
Valley Forge, PA 19482 michael_drayo@vanguard.com
Statement of Additional Information Comments
Comment 4: Please update all financial information as of the most recent fiscal year end where appropriate.
Response: We have updated all financial information as of the most recent fiscal year end where appropriate.
Comment 5: On page B"83, include a reference to "High Yield Bond Portfolio" in the list of portfolios; a portion of the assets of which are advised by Vanguard.
Response: We have revised the disclosure accordingly.
If you have any questions, please contact me at michael_drayo@vanguard.com.
Sincerely,
/s/ Michael Drayo
Michael Drayo
Associate General Counsel
The Vanguard Group, Inc.
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