Correspondence 0001193125-24-019223 from LINCOLN VARIABLE INSURANCE PRODUCTS TRUST (CIK 0000914036)
LINCOLN VARIABLE INSURANCE PRODUCTS TRUST (CIK 0000914036)
Date: Jan. 30, 2024 · CIK: 0000914036 · Accession: 0001193125-24-019223
AI Filing Summary & Sentiment
File numbers found in text: 811-08090
Letter
VIA EDGAR Division of Investment Management Securities and Exchange Commission File Nos.: 033-70742 and 811-08090 Series: LVIP T. Rowe Price Growth Stock Fund (the “Fund”)
Dear Mr. Zapata:
This letter responds to your comments, provided via phone on January 29, 2024, to the Registrant’s preliminary proxy statement filing on January 19, 2024, pursuant to Section 14(a) of the Securities Exchange Act of 1934 (the “Proxy Statement”).
The following are your comments and the Registrant’s responses.
1) Please clarify in the section entitled, “Reason for the Proposal”, whether the initiative was proposed by the Board or the Adviser.
A. The requested revision has been made. The Proxy Statement has been updated to read as follows:
The Adviser has proposed to change this fundamental investment restriction as follows:
2) In the section entitled, “Approval of Proposal”, please clarify whether the Board considered alternatives to the proposal or other relevant factors while reviewing the proposal.
A. The requested revision has been made. The Proxy Statement has been updated to read as follows:
The Board also considered the alternative of retaining the existing fundamental investment restriction. The Board considered all relevant factors, including the potential impact on the Fund and its risk profile, Fund disclosure changes, tax considerations, and the estimated costs associated with seeking shareholder approval of the proposed change for the Fund.
3) Please update the share information on page six of the Proxy Statement.
A. The requested revision has been made.
Lincoln Financial Group
150 N. Radnor Chester Rd.
Radnor, PA
Phone: 484-583-8711
Email: sam.goldstein@lfg.com
4) Please update the investment adviser and subadviser assets under management information as of December 31, 2023.
A. The requested revision has been made.
Your consideration of this filing is much appreciated. Please contact me at the number indicated above with any questions.
Very truly yours,
/s/Samuel K. Goldstein
Show Raw Text
CORRESP 1 filename1.htm Lincoln Variable Insurance Products Trust Phone: 484-583-8711 Email: sam.goldstein@lfg.com Lincoln Financial Group 150 N. Radnor Chester Rd. Radnor, PA 19087 VIA EDGAR January 30, 2024 Alberto Zapata, Esq. Division of Investment Management Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549-4644 RE: Registrant: Lincoln Variable Insurance Products Trust (the “Registrant”) File Nos.: 033-70742 and 811-08090 Series: LVIP T. Rowe Price Growth Stock Fund (the “Fund”) Dear Mr. Zapata: This letter responds to your comments, provided via phone on January 29, 2024, to the Registrant’s preliminary proxy statement filing on January 19, 2024, pursuant to Section 14(a) of the Securities Exchange Act of 1934 (the “Proxy Statement”). The following are your comments and the Registrant’s responses. 1) Please clarify in the section entitled, “Reason for the Proposal”, whether the initiative was proposed by the Board or the Adviser. A. The requested revision has been made. The Proxy Statement has been updated to read as follows: The Adviser has proposed to change this fundamental investment restriction as follows: 2) In the section entitled, “Approval of Proposal”, please clarify whether the Board considered alternatives to the proposal or other relevant factors while reviewing the proposal. A. The requested revision has been made. The Proxy Statement has been updated to read as follows: The Board also considered the alternative of retaining the existing fundamental investment restriction. The Board considered all relevant factors, including the potential impact on the Fund and its risk profile, Fund disclosure changes, tax considerations, and the estimated costs associated with seeking shareholder approval of the proposed change for the Fund. 3) Please update the share information on page six of the Proxy Statement. A. The requested revision has been made. 1 Lincoln Financial Group 150 N. Radnor Chester Rd. Radnor, PA 19087 Phone: 484-583-8711 Email: sam.goldstein@lfg.com 4) Please update the investment adviser and subadviser assets under management information as of December 31, 2023. A. The requested revision has been made. Your consideration of this filing is much appreciated. Please contact me at the number indicated above with any questions. Very truly yours, /s/Samuel K. Goldstein Samuel K. Goldstein, Esq. Chief Counsel – Funds Management Enclosures cc: Ronald A. Holinsky, Esq. Christian Pfeiffer, Esq. Sharon Alyanakian Teriana Griggs 2