SEC Company Response from STI CLASSIC VARIABLE TRUST (CIK 0000944487) — May 26, 2005
STI CLASSIC VARIABLE TRUST (CIK 0000944487)
Date: May 26, 2005 · CIK: 0000944487 · Accession: 0000950152-05-004738
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STI CLASSIC VARIABLE TRUST
3435 Stelzer Road
Columbus, Ohio 43219
May 4, 2005
Via EDGAR Correspondence & Regular Mail
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U.S. Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0901
Attention: Mr. Jason Fox, Staff Accountant
Office of Disclosure & Review
U.S. Securities and Exchange Commission
Dear Mr. Fox:
On April 29,2005, we received via a conference call comments (the "Comments") to
the Form N-CSR filed by the STI Classic Variable Trust (the "Trust") for the
fiscal year ended December 31, 2004. You noted that "the comments were related
to best practice" in the Form N-CSR filed by the Trust.
You requested the written responses to the Comments be filed via EDGAR
correspondence within thirty days. This letter is intended to respond to the
Comments on behalf of the Trust and makes reference to sections of the Trust's
December 31, 2004 annual report as filed via EDGAR with the Securities and
Exchange Commission (the "SEC") on March 2, 2005.
To assist you with your review, we have preceded each of our responses with the
relative comment.
COMMENT 1: WITHIN THE MANAGEMENT'S DISCUSSION OF FUND PERFORMANCE SECTION
(MDFP), INCLUDE A STATEMENT REFLECTING THAT THE RETURNS DO NOT INCLUDE THE
CHARGES/EXPENSES OF THE INSURANCE PRODUCT AND IF THEY DID THEY WOULD BE LOWER.
Response:
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Although the presentation within the MDFP conforms to the disclosure
requirements, Management has agreed to include the added language in future
filings.
COMMENT 2: IN THE EXPENSE EXAMPLES, INCLUDE A STATEMENT REFLECTING THAT THE
EXPENSES DO NOT INCLUDE THE CHARGES/EXPENSES OF THE INSURANCE PRODUCT AND IF
THEY DID THEY WOULD BE HIGHER.
Response:
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Although the presentations within the expense examples conform to the disclosure
requirements, Management has agreed to include the added language in future
filings.
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In connection with the Comments, our responses thereto, and all future filings
of Form N-CSR and Form N-Q, as appropriate, management of the Trust acknowledges
that:
- the Trust is responsible for the adequacy and accuracy of the
disclosure in the filings;
- comments from the staff of the SEC (the "Staff") or changes to
disclosure in response to Staff comments in the filings reviewed by the
Staff do not foreclose the SEC from taking any action with respect to
the filing; and
- the Trust may not assert Staff comments as a defense in any proceeding
initiated by the SEC or any person under the federal securities laws of
the United States.
We trust that this information will be of assistance. Please contact the
undersigned at (614) 470-8071 with any questions.
Respectfully submitted,
Bryan Haft
Treasurer, STI Classic Variable Trust
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