Correspondence 0000878467-25-000007 from VARIABLE INSURANCE PRODUCTS FUND III (CIK 0000927384)
VARIABLE INSURANCE PRODUCTS FUND III (CIK 0000927384)
Date: Feb. 12, 2025 · CIK: 0000927384 · Accession: 0000878467-25-000007
AI Filing Summary & Sentiment
File numbers found in text: 811-07205
Letter
VIA EDGAR RE: Variable Insurance Products Fund III (the trust): File Nos. 033-54837 and 811-07205 Growth & Income Portfolio, Growth Opportunities Portfolio, and Value Strategies Portfolio (the fund(s)) Post-Effective Amendment No. 67
Dear Ladies and Gentlemen:
On behalf of Variable Insurance Products Fund III (the “Registrant”), Post-Effective Amendment No. 67 (the “Amendment”) to the Registrant’s registration statement on Form N-1A under the Securities Act of 1933 Act, as amended (the “Securities Act”), was electronically transmitted for filing pursuant to Rule 485(a) on February 10, 2025 Accession No. 0000927384-25-000010. The Amendment has been filed solely for the purpose of implementing certain disclosure changes in connection with recent amendments to Rule 35d-1 under the Investment Company Act of 1940, as amended (the “Investment Company Act”) (the “Names Rule”).
We hereby request, in reliance upon Securities Act Release No. 6510 and Investment Company Act Release No. 13768 (February 15, 1984), that the Amendment receive selective review from the SEC and its Staff of the changes contained herein. The Amendment reflects the implementation of changes in connection with amendments to the Names Rule, and, aside from the sections highlighted below, each fund’s prospectus(es) and SAI(s) are “not substantially different” from the disclosures that were previously filed in Post-Effective Amendment No. 66 (Accession No. 0000927384-24-000051) to the Trust’s registration statement on N-1A. The sections of the Amendment that include substantive differences from the prior disclosure include: (i) the Principal Investment Strategies sections of the Fund Summary section in the prospectus; and (ii) the Principal Investment Strategies and Description of Principal Security Types sections in the Investment Details section of the prospectus.
Please contact Renée Fuller at (603) 721-4221 with any questions or comments regarding this Amendment.
Sincerely,
/s/Renée Fuller
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CORRESP 1 filename1.htm Converted by EDGARwiz 245 Summer Street Boston, MA 02210 Fidelity® Investments ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||| February 12, 2025 VIA EDGAR U.S. Securities & Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 RE: Variable Insurance Products Fund III (the trust): File Nos. 033-54837 and 811-07205 Growth & Income Portfolio, Growth Opportunities Portfolio, and Value Strategies Portfolio (the fund(s)) Post-Effective Amendment No. 67 Dear Ladies and Gentlemen: On behalf of Variable Insurance Products Fund III (the “Registrant”), Post-Effective Amendment No. 67 (the “Amendment”) to the Registrant’s registration statement on Form N-1A under the Securities Act of 1933 Act, as amended (the “Securities Act”), was electronically transmitted for filing pursuant to Rule 485(a) on February 10, 2025 Accession No. 0000927384-25-000010. The Amendment has been filed solely for the purpose of implementing certain disclosure changes in connection with recent amendments to Rule 35d-1 under the Investment Company Act of 1940, as amended (the “Investment Company Act”) (the “Names Rule”). We hereby request, in reliance upon Securities Act Release No. 6510 and Investment Company Act Release No. 13768 (February 15, 1984), that the Amendment receive selective review from the SEC and its Staff of the changes contained herein. The Amendment reflects the implementation of changes in connection with amendments to the Names Rule, and, aside from the sections highlighted below, each fund’s prospectus(es) and SAI(s) are “not substantially different” from the disclosures that were previously filed in Post-Effective Amendment No. 66 (Accession No. 0000927384-24-000051) to the Trust’s registration statement on N-1A. The sections of the Amendment that include substantive differences from the prior disclosure include: (i) the Principal Investment Strategies sections of the Fund Summary section in the prospectus; and (ii) the Principal Investment Strategies and Description of Principal Security Types sections in the Investment Details section of the prospectus. Please contact Renée Fuller at (603) 721-4221 with any questions or comments regarding this Amendment. Sincerely, /s/Renée Fuller Renée Fuller Shareholder Reporting