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Correspondence 0001193125-24-255279 from LINCOLN VARIABLE INSURANCE PRODUCTS TRUST (CIK 0000914036)

LINCOLN VARIABLE INSURANCE PRODUCTS TRUST (CIK 0000914036)
Date: Nov. 12, 2024 · CIK: 0000914036 · Accession: 0001193125-24-255279

AI Filing Summary & Sentiment

File numbers found in text: 811-08090

Date
November 12, 2024
Author
/s/ Christian A. Pfeiffer
Form
CORRESP
Company
LINCOLN VARIABLE INSURANCE PRODUCTS TRUST (CIK 0000914036)

Letter

VIA EDGAR Division of Investment Management Securities and Exchange Commission File Nos.: File Nos. 033-70742 and 811-08090 Funds: LVIP MFS International Equity Managed Volatility Fund (the “Fund”)

Dear Mr. Zapata:

This letter responds to your comments, provided via phone on November 08, 2024, to the Registrant’s registration statement filed on Form 485APOS on September 19, 2024, under Rule 485(a) under the Securities Act of 1933 (the “Registration Statement”).

The following are your comments and the Registrant’s responses.

1) Please confirm that the Fund’s expense limitation will run through April 30, 2026.

a) Confirmed.

2) Please ensure that references to underlying fund investment strategies are clearly defined throughout the discussion of the Fund’s principal investment strategy.

a) The requested revisions have been made.

3) Please define “international universe” as it is used in the principal investment strategy of the relevant underlying fund holding.

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/ Christian A. Pfeiffer

Show Raw Text
CORRESP
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Lincoln Variable Insurance Products Trust

 Lincoln Financial Group

150 N. Radnor Chester Rd.

 Radnor, PA
19087

 Phone: (603) 368-7352

Email: christian.pfeiffer@lfg.com

 VIA EDGAR

November 12, 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 (“Trust”)

 File Nos.:

 File Nos. 033-70742 and 811-08090

 Funds:

 LVIP MFS International Equity Managed Volatility Fund (the
“Fund”)

Dear Mr. Zapata:

 This letter responds to your comments,
provided via phone on November 08, 2024, to the Registrant’s registration statement filed on Form 485APOS on September 19, 2024, under Rule 485(a) under the Securities Act of 1933 (the “Registration Statement”).

The following are your comments and the Registrant’s responses.

1)
 Please confirm that the Fund’s expense limitation will run through April 30, 2026.

a)
 Confirmed.

2)
 Please ensure that references to underlying fund investment strategies are clearly defined throughout the
discussion of the Fund’s principal investment strategy.

a)
 The requested revisions have been made.

3)
 Please define “international universe” as it is used in the principal investment strategy of the
relevant underlying fund holding.

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/ Christian A. Pfeiffer

Christian A. Pfeiffer, Esq.

Counsel – Funds Management

cc:
 Ronald A. Holinsky, Esq.

 
 Samuel K. Goldstein, Esq.

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