Correspondence 0000930413-23-002383 from FIRST EAGLE VARIABLE FUNDS (CIK 0001000249)
FIRST EAGLE VARIABLE FUNDS (CIK 0001000249)
Date: Oct. 27, 2023 · CIK: 0001000249 · Accession: 0000930413-23-002383
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 811-09092
Letter
Division of Investment Management, Office of the Chief Accountant 100 F. Street, N.E. Washington, DC 20549 Re: First Eagle Variable Funds (the “Trust” and the sole series of the Trust, the “Fund”) File Nos.: 033-96668 and 811-09092
Dear Mr. Kernan:
Thank you for your comments regarding the Annual Report on Form N-CSR of the Fund, filed with the Securities and Exchange Commission on March 8, 2023. This letter responds to your comments, which you provided to us by telephone on September 26, 2023.
1. COMMENT: Please clarify if the Fund’s investment in gold bullion are held through a wholly owned subsidiary whose activities are consolidated into the financial statements of the Fund. If appliable, for a consolidated fund, please include the appropriate disclosures consistent with US GAAP, Reg. S-X and other accounting guidance. If the Fund’s investment in gold bullion is made through any unconsolidated subsidiary acting as an extension of the Fund’s investment operations, please explain why the Fund did not consolidate any such subsidiaries.
RESPONSE: The Fund’s investment in gold bullion are not held through any subsidiary.
2. COMMENT: It appears that the Fund’s investments in gold bullion are held in a wholly owned subsidiary, which financials may be consolidated. However, the auditor’s opinion and internal control report does not reference consolidated financial statements. Please confirm that PwC did in fact audit the consolidated financial statements and ensure that the opinion and internal control report mentions the consolidated financials on a going forward basis, as appliable.
RESPONSE: The Fund’s investment in gold bullion are not held through any subsidiary.
Sidley Austin (NY) LLP is a Delaware limited liability partnership doing business as Sidley Austin LLP and practicing in affiliation with other Sidley Austin partnerships.
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Should you have any follow-up questions concerning this letter, please do not hesitate to contact me at (212) 839-8679.
Sincerely,
/s/ Matthew Kutner
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Sidley
Austin LLP
787
Seventh Avenue
New
York, NY 10019
+1
212 839 5300
+1
212 839 5599 Fax
AMERICA ·
ASIA PACIFIC · EUROPE
+1
212 839 8679
MKUTNER@sidley.com
October 27, 2023
John Kernan
Staff Accountant
U.S. Securities and Exchange Commission
Division of Investment Management, Office of the Chief Accountant
100 F. Street, N.E.
Washington, DC 20549
Re: First Eagle Variable Funds (the “Trust”
and the sole series of the Trust, the “Fund”)
File Nos.: 033-96668 and 811-09092
Dear Mr. Kernan:
Thank you for your
comments regarding the Annual Report on Form N-CSR of the Fund, filed with the Securities and Exchange Commission on March 8, 2023. This
letter responds to your comments, which you provided to us by telephone on September 26, 2023.
1. COMMENT: Please clarify if the Fund’s investment in gold bullion are held through a wholly
owned subsidiary whose activities are consolidated into the financial statements of the Fund. If appliable, for a consolidated fund, please
include the appropriate disclosures consistent with US GAAP, Reg. S-X and other accounting guidance. If the Fund’s investment in
gold bullion is made through any unconsolidated subsidiary acting as an extension of the Fund’s investment operations, please explain
why the Fund did not consolidate any such subsidiaries.
RESPONSE: The Fund’s investment
in gold bullion are not held through any subsidiary.
2. COMMENT: It appears that the Fund’s investments in gold bullion are held in a wholly owned subsidiary, which financials
may be consolidated. However, the auditor’s opinion and internal control report does not reference consolidated financial statements.
Please confirm that PwC did in fact audit the consolidated financial statements and ensure that the opinion and internal control report
mentions the consolidated financials on a going forward basis, as appliable.
RESPONSE: The Fund’s investment
in gold bullion are not held through any subsidiary.
Sidley Austin (NY) LLP is a Delaware limited liability partnership doing business as Sidley Austin LLP and practicing in affiliation with other Sidley Austin partnerships.
Page 2
****
Should you have any follow-up questions concerning
this letter, please do not hesitate to contact me at (212) 839-8679.
Sincerely,
/s/ Matthew Kutner
Matthew J. Kutner (as Attorney for the Fund)
cc:
Sheelyn Michael, Deputy General Counsel, First Eagle Investment Management,
LLC
Nathan J. Greene, Sidley Austin LLP