Correspondence 0001193125-23-220986 from PIMCO VARIABLE INSURANCE TRUST (CIK 0001047304)
PIMCO VARIABLE INSURANCE TRUST (CIK 0001047304)
Date: Aug. 25, 2023 · CIK: 0001047304 · Accession: 0001193125-23-220986
AI Filing Summary & Sentiment
File numbers found in text: 811-08399, 811-22376
Letter
VIA EDGAR Division of Investment Management Washington, D.C. 20549 Re: PIMCO Equity Series VIT, Investment Company Act File No. 811-22376 PIMCO Variable Insurance Trust, Investment Company Act File No. 811-08399 (each a “Registrant” and each series thereof a “Fund”)
Dear Mr. Ellington:
In a telephone conversation with Adam Schlichtmann of Ropes & Gray LLP on Wednesday, August 2, 2023, you communicated the Securities and Exchange Commission staff’s (the “Staff”) comments on the most recent annual reports for the Registrants following a review of the Registrants’ recent Form N-CSR filings.1 A summary of the Staff’s comments, along with the Registrants’ responses, is set forth below.
Comment 1: For variable funds, please add a footnote to the financial highlights stating that the performance disclosed does not include fees and expenses imposed by variable contracts.
Response: The Registrants will include disclosure in future reports indicating that performance presented in the financial highlights does not include fees and expenses imposed by variable contracts.
Comment 2: In future N-CSR filings, please include responses to Items 4(i) and (j). If there is nothing to report in response to either item, please indicate “not applicable” or use “N/A.”
Response: The Registrants will add the relevant disclosure for future reports.
* * *
We believe that the foregoing has been responsive to the Staff’s comments. Please call the undersigned at (202) 261-3464 if you wish to discuss this correspondence further.
Sincerely,
/s/ Adam T. Teufel
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CORRESP 1 filename1.htm CORRESP 1900 K Street, NW Washington, DC 20006-1110 +1 202 261 3300 Main +1 202 261 3333 Fax www.dechert.com August 25, 2023 VIA EDGAR Kenneth Ellington Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: PIMCO Equity Series VIT, Investment Company Act File No. 811-22376 PIMCO Variable Insurance Trust, Investment Company Act File No. 811-08399 (each a “Registrant” and each series thereof a “Fund”) Dear Mr. Ellington: In a telephone conversation with Adam Schlichtmann of Ropes & Gray LLP on Wednesday, August 2, 2023, you communicated the Securities and Exchange Commission staff’s (the “Staff”) comments on the most recent annual reports for the Registrants following a review of the Registrants’ recent Form N-CSR filings.1 A summary of the Staff’s comments, along with the Registrants’ responses, is set forth below. Comment 1: For variable funds, please add a footnote to the financial highlights stating that the performance disclosed does not include fees and expenses imposed by variable contracts. Response: The Registrants will include disclosure in future reports indicating that performance presented in the financial highlights does not include fees and expenses imposed by variable contracts. Comment 2: In future N-CSR filings, please include responses to Items 4(i) and (j). If there is nothing to report in response to either item, please indicate “not applicable” or use “N/A.” Response: The Registrants will add the relevant disclosure for future reports. * * * We believe that the foregoing has been responsive to the Staff’s comments. Please call the undersigned at (202) 261-3464 if you wish to discuss this correspondence further. Sincerely, /s/ Adam T. Teufel 1 The Registrants’ most recent annual filings on Form N-CSR, for the period ending December 31, 2022, were each filed on March 1, 2023. Kenneth Ellington August 25, 2023 Page 2 Adam T. Teufel cc: Ryan Leshaw, Pacific Investment Management Company LLC Timothy Bekkers, Pacific Investment Management Company LLC