SecProbe.io

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October 25, 2005

Tony Burak
Division of Investment Company
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549-0506

Re:      Schwab Annuity Portfolios (File No. 811-08314)
         Form N-CSR

Dear Mr. Burak:

Set forth below are your  comments,  which you  provided by telephone on October
14, 2005, and our responses to your  comments,  on Form N-CSR for Schwab Annuity
Portfolios as of December 31, 2004. Both the comments and responses are based on
the  annual  shareholder  reports,  which were  filed  with the  Securities  and
Exchange Commission on March 8, 2005.

1.       Comment:  In the "Portfolio Expenses - Examples for a $1,000
         Investment" section, please add a footnote similar to footnote 1 in the
         "Performance" section related to the insurance contract fees.

         Response:  In response to your  request,  we have reviewed the footnote
         language  quoted  in the  "Performance"  section.  As a result  of this
         review, we will add the following footnote in the "Portfolio  Expenses"
         section in future reports: "Expenses do not reflect the additional fees
         and  expenses  imposed  by the  insurance  company  under the  variable
         insurance  product  contract.  If those contract fees and expenses were
         included, the expenses would be more than those shown."

2.       Comment:  Please provide additional statement of availability of the
         funds' proxy voting record in the 'Proxy Voting Policies and
         Procedures' paragraph.

         Response:  The  disclosure of  availability  of proxy voting record was
         added in the semi-annual  shareholder  reports as of June 30, 2005. The
         disclosure  reads as follows:  "Information  regarding how a fund voted
         proxies  relating  to  portfolio  securities  during  the  most  recent
         twelve-month  period ended June 30 is  available,  without  charge,  by
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Tony Burak
October 25, 2005
Page 2

         visiting  Schwab's website at  www.schwab.com/schwabfunds  or the SEC's
         website at http://www.sec.gov. This statement will also be disclosed in
         future shareholder reports.

3.       Comment:  Please clarify where the funds' Forms N-Q were posted on the
         Schwab website.

         Response:   It  is  Schwab's   practice  not  to  post  Schwab  Annuity
         Portfolios' Forms N-Q on the web because they are only available to the
         insurance companies.  Since web posting is not required, we will delete
         the  language  related  to the  availability  of Form N-Q on the Schwab
         website  in  the  introductory  paragraph  under  'Portfolio  Holdings'
         section in future reports.

4.       Comment:  Please  separately  disclose  'Investments  with affiliates'
         under  'Investments,  at value' line in the  'Statement  of Assets and
         Liabilities',  and 'Dividends  received from underlying  funds' in the
         'Statement of Operations' for the Schwab  MarketTrack Growth
         Portfolio II.

         Response:  This fund operates  pursuant to an exemptive order issued by
         the SEC for its affiliated  fund of funds structure which was disclosed
         in the  'Financial  Notes'  section.  In addition,  all the  affiliated
         underlying funds were highlighted in the 'Portfolio  Holdings' section.
         Therefore,  while the current  report  does  disclose  affiliated  fund
         holdings,  we will separately disclose 'Investments with affiliate' and
         'Dividends received from underlying funds' in the financial  statements
         of future reports.

5.       Comment:  There  were  two  money  fund  investments  in the  S&P  500
         Portfolio.  Please  disclose the 'Underlying  funds valuation  method'
         under the 'Accounting Policies' in the 'Financial Notes' section.

         Response:  The two  unaffiliated  money fund investments in the S&P 500
         Portfolio  were short term  investments  related to the  collateral for
         securities on loan and the sweep  vehicle for daily excess cash.  Since
         this fund does not operate under a fund of funds  structure,  we do not
         believe that an 'underlying fund valuation'  disclosure is appropriate.
         We have disclosed the collateral  investments for securities on loan in
         the 'Financial  Notes' section and will provide more information on the
         sweep vehicle and its valuation method in future reports.

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Tony Burak
October 25, 2005
Page 3

I hereby  acknowledge  on behalf of the Trust that: (i) the Trust is responsible
for the adequacy and accuracy of the disclosure in its shareholder reports; (ii)
SEC staff comments or changes to disclosure in response to staff comments in the
shareholder  reports  reviewed by the staff do not foreclose the SEC from taking
any action with respect to the registration  statement;  and (iii) the Trust may
not assert SEC staff  comments as a defense in any  proceeding  initiated by the
SEC or any person under the federal securities laws of the United States.

Please do not hesitate to call the undersigned with any questions or comments.

Very truly yours,

/s/ George Pereira
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George Pereira
Treasurer
Schwab Annuity Portfolios
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