SecProbe.io

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      Stradley Ronon Stevens & Young, LLP

      2005 Market Street

      Suite 2600

      Philadelphia, PA 19103

      Telephone  215.564.8000

      Fax  215.564.8120

      www.stradley.com

      Kenneth L Greenberg

      Partner

      kgreenberg@stradley.com

      215.564.8149

    January 17, 2023

    VIA EDGAR

    U.S. Securities and Exchange Commission

    Division of Investment Management

    100 F Street, N.E.

    Washington, D.C.  20549-9303

    Attention:                          Mark A. Cowan, Esq.

          Re:

            Allianz Variable Insurance Products Fund of Funds Trust (File No. 333-268901) and Allianz Variable Insurance Products Trust (File No. 333-268900)

    Dear Mr. Cowan:

    This letter provides the responses of the Allianz Variable Insurance Products Fund of Funds Trust (“VIP FoF
      Trust” or a “Registrant”) and the Allianz Variable Insurance Products Trust (“VIP Trust” or a “Registrant” and together with VIP FoF Trust, the “Registrants”) to the disclosure comments that I received on January 10, 2023 from Mark A. Cowan, Esq.,
      the staff disclosure reviewer,  on the Registration Statement on Form N-14 (the “Registration Statement”) of VIP FoF Trust.  Comments and responses on VIP FoF Trust’s Registration Statement also apply to the Registration Statement of  the VIP Trust.
      The Registration Statements were filed with the Securities and Exchange Commission (“SEC”) on December 20, 2022 under the Securities Act of 1933 (the “Securities Act”).

    Below I have included Mr. Cowan’s comments and the Registrants’ responses (in bold) to each comment.  Capitalized terms not defined herein have the same meaning as in the Registration Statement.

    Comments on the Joint Information Statement/Prospectus

          1.

            Comment:  We question whether the Registrants may rely on the Janus Aspen Series no-action letter (pub. avail. April 10, 2008) due to the disclosure that certain Funds will bear the costs of the Reorganization.  Please explain the basis for such reliance.

              Philadelphia, PA • Malvern, PA • Cherry Hill, NJ • Wilmington, DE •
                Washington, DC • New York, NY • Chicago, IL

              A Pennsylvania Limited Liability Partnership

        Mark A. Cowan, Esq.

        U.S. Securities and Exchange Commission

        January 17, 2023

        Page 2

    Response:
      After further discussions with the SEC staff and the Investment Manager, the Investment Manager has agreed to pay the costs of the Reorganizations including repositioning costs.  In light of this change, the Registrants believe that it has addressed
      the SEC staff’s concerns regarding its reliance on the Janus no-action letter.

          2.

            Text:  The first sentence of the second paragraph of the Shareholder Letter states:

    “The Boards of Trustees of the VIP Trust and the VIP FoF Trust approved the
      reorganizations regarding the following series of the Trusts into another series of the Trusts, as follows:”

    Comment:
      Insert the word “unanimously” before the word “approved.”

    Response:
      Revised as requested.

          3.

            Text:  Table listing the Reorganizations in the Shareholder Letter- in particular, the Reorganization of
              the AZL® MSCI Emerging Markets Equity Index Fund into the AZL® International Index Fund.

    Comments:  The reviewer noted that:

    (a)  this particular Reorganization involves shareholders moving from a fund tracking performance of an emerging
      market index to that of a developed market index, which appears to be a significant shift in strategy;

    (b) the Board considerations disclosure characterizes these funds as "substantially similar" based on each Fund
      using a passive management style to track the performance of an index comprised of foreign equity securities, but then notes the difference between exposure to emerging markets versus developed markets and associated risks; and

    (c)  the entire portfolio is being liquidated and converting to cash.

    In light of the foregoing:

    1) Disclosure regarding this Reorganization should highlight where applicable that the
      Acquiring Fund is not similar to the Acquired Fund in terms of investments, risks and exposure to emerging markets.

    2) Please explain
        supplementally how the Reorganization of the AZL® MSCI Emerging Markets Equity Index Fund (“Emerging Markets Fund”) is in the best interests of the
        contract owners.

        Mark A. Cowan, Esq.

        U.S. Securities and Exchange Commission

        January 17, 2023

        Page 3

    3) In light of the Registrants’ reliance on the Janus no-action letter, we believe the Manager
      should pick up all of the costs of liquidating the portfolio and converting to cash.

    Responses:

    1)  Revised as requested.

          2)

            The Board determined that the Reorganization would be in the best interest of
                shareholders based on the totality of the information as to all of the factors described under the section titled “REASONS FOR THE PROPOSED REORGANIZATION AND BOARD DELIBERATIONS.” Such factors included,
              but were not limited, to the declining assets of the Emerging Markets Fund, the ability of shareholder to retain an investment that uses an indexing strategy whose principal investments were foreign securities albeit developed markets
              securities rather than emerging markets securities; the relative performance of the Acquired Fund versus the Acquiring Fund; the lower expenses of the Acquiring Fund; and the tax consequences of the Reorganization. As disclosed in the Joint
              Information Statement/ Prospectus, in its deliberations, the Board did not identify any single factor that was paramount or controlling and individual Board members may have attributed different weights to various factors.

    3)  The Manager has agreed to pick up all of the costs of liquidating the
      portfolio and converting to cash.

          4.

            Text:  Second sentence of the fourth paragraph of the Shareholder letter states:

    These reasons include low and declining assets, unsatisfactory
      long-term investment performance, portfolio manager changes in sub-advisors, and/or the need to simplify the variable annuity investment option lineup.

    Comment: Please delete the reference to the need to simplify the variable annuity investment option lineup.  The Board did not consider it as a factor
        when approving the Reorganizations, and we do not see it as an appropriate factor to be weighted in determining whether the transaction is in the best interest of contract owners.  This factor benefits the Manager.

    Response:  Revised as requested.

          5.

            Text:  The second sentence of the second full paragraph on the second page of the Shareholder Letter
              states:

        Mark A. Cowan, Esq.

        U.S. Securities and Exchange Commission

        January 17, 2023

        Page 4

    “To accomplish each proposed reorganization, the Board of Trustees of each Acquired Fund
      has approved an Agreement and Plan of Reorganization.”

    Comment:
      Insert the word “unanimously” before the word “approved.”

    Response:  Revised as requested.

          6.

            Text:  Third full paragraph of the second page of the Shareholder states:

    “Any such transfers will be subject to the restrictions on
      investment option allocations set forth in your Contract.”

    Comment:
      Please explain more clearly what restrictions are being referred to.

    Response:
      There are a wide variety of investment allocation restrictions imposed by different contracts and related optional benefits and it is not practical to describe them.  The Registrants believe that the disclosure is sufficient for alerting contract
      holders that certain restrictions may apply to them.

          7.

            Text:  Last sentence of the first full paragraph under the question “Why are Reorganizations being
              proposed?” in the Joint Information Statement/Prospectus Q&A states:

    “Each Acquiring Fund, except for the MVP DFA Multi-Strategy Fund is
      larger than its corresponding Acquired Fund.”

    Comment:
      Should “AZL” be inserted immediately before MVP?

    Response:  Revised as requested.

          8.

            Text:  Last paragraph under the question “Why are Reorganizations being proposed?” in the Joint
              Information Statement/Prospectus Q&A states:

    “There are some significant differences in the investment strategies and risks of the
      Funds, which are described in the accompanying Joint Information Statement/Prospectus. You should consider consulting with your financial professional to discuss your options for transferring contract value to other investment options available under
      your contract.”

    Comment:  Consider briefly highlighting the significant differences here (similar to what was done above).

    Response:  Revised as requested.

        Mark A. Cowan, Esq.

        U.S. Securities and Exchange Commission

        January 17, 2023

        Page 5

          9.

            Text:  The second and third sentences under the question “Will the expenses of the Fund in which I
              participate increase as a result of the Reorganization?” in the Joint Information Statement/Prospectus Q&A states:

    “The management fees and total expense ratio paid by each Acquiring Fund are lower than
      those paid by the corresponding Acquired Fund.  Specific detail with respect to each Reorganization combination is  shown in the pro forma fee tables starting
      on page 46 of the enclosed Joint Information Statement/Prospectus.”

    Comments:

    (a) The management fees are
        the same (not lower) with respect to the Reorganization of the AZL MVP Fusion Moderate Fund into AZL MVP DFA Multi-Strategy Fund.  Please revise the disclosure accordingly.  In this regard, if the management fee is just lower because of fee waiver
        and/or expense reimbursement, the disclosure should be clear about the reduction due to the waiver and/or expense reimbursement and that fees could go up after their termination.  There appears to be other Reorganizations where fee and expenses
        could become higher after expiration of the waiver or expenses reimbursement.  We suggest for each Reorganization, providing the pro forma total gross and net (after fee waiver) so contract owners can see that fee and expenses could be higher after expiration of the waiver or expenses reimbursement.

    (b)  The
        disclosure should also specify for each Reorganization where there is a fee and/or expense reduction due to the waiver and/or expense reimbursement that the fees and expenses could increase after April 30, 2024 when the fee waiver and/or expense
        reimbursement agreement, as applicable, terminates.

          (c)

            Double check the accuracy of the page reference in the paragraph.

    Responses:

    (a) The Registrants have revised disclosure to
      indicate that the management fees are the same with respect to the Reorganization of the AZL MVP Fusion Moderate Fund into AZL MVP DFA Multi-Strategy Fund.  For those
        Reorganizations where annual fund operating fees and expenses could become higher after expiration of a waiver or expenses reimbursement,  disclosure has been added to note that such annual fund operating fees and expenses could increase after the
        termination of the waiver and/or expense reimbursement.  The Registrants have also included in the Summary a chart that compares each Acquired Fund’s total gross and net annual fund operating expenses with the  pro forma total gross and net annual fund operating expenses so contract owners will be
        able to see that annual fund

        Mark A. Cowan, Esq.

        U.S. Securities and Exchange Commission

        January 17, 2023

        Page 6

    operating fees and expenses could be higher after
      expiration of the waiver and/or expenses reimbursement.

    (b)  Revised as requested.

    (c) The Registrants will double check the
      accuracy of the page reference in the paragraph and correct it if needed.

          10.

            Text:  The first two sentences of the first paragraph under the question “Who is paying the costs of the
              Reorganizations?” of the Joint Information Statement/Prospectus Q&A states

    Costs related to each Reorganization (including any transaction costs related to
      repositioning of the portfolios in connection with the Reorganization) are estimated to be approximately as set forth in the table below. Costs related to the Reorganization of the AZL DFA Five-Year Global Fixed Income Fund and the AZL MetWest Total
      Return Bond Fund will be paid by Allianz Investment Management LLC, the Funds’ investment manager (the “Manager”).

    Comments:

          (a)

            Please confirm that each Reorganization is consistent with the Janus Aspen Series no-action letter (pub. avail. April 10, 2008).  It appears that in at least a
                couple of these reorgs that Fund investors might be bearing the costs of the Reorganization (other than brokerage expenses).  We believe that under Janus, the Manager should be paying all the costs of the Reorganizations.  While we have not objected to brokerage costs being paid by contract owners, we think that in the
                case of the Emerging Markets Fund Reorganization where the Fund is selling off its portfolio and converting to cash, the Manager should be paying all the Reorganization costs, and not carve out brokerage costs.  Please revise the paragraph
                to disclose that Manager is picking up costs of all the Reorganizations.

          (b)

            In the table that follows the paragraph which provides the estimated costs of the Reorganization, please show repositioning costs for each merger on an aggregate and
              per share basis and note that Manager is going to pay such repositioning costs as part of the Reorganization costs.  We note that the only repositioning cost figure is the $280,000 figure in footnote 1 to the table and relates only to
              Emerging Markets Fund.  Are there no repositioning costs to report for the other reorgs?

    Response:
      As noted above, after further discussions with the SEC staff and the Investment Manager, the Investment Manager has agreed to pay the costs of the Reorganizations including repositioning costs.  In light of this change, the

        Mark A. Cowan, Esq.

        U.S. Securities and Exchange Commission

        January 17, 2023

        Page 7

    Registrants believe that it has addressed the SEC staff’s concerns regarding its reliance
      on the Janus no-action letter.  The paragraph and related table have been revised to disclose
        that the Manager is picking up costs of all of the Reorganizations including repositioning costs.

          11.

            Text:  The third and fourth sentences of the first paragraph under the question “Who is paying the costs
              of the Reorganizations?” in the Joint Information Statement/Prospectus Q&A states:

    “It is anticipated that the AZL MVP Fusion Balanced Fund, AZL MVP Fusion Conservative
      Fund and AZL MVP Fusion Moderate Fund (collectively, the “Fusion Funds”) will redeem their shares in the AZL MSCI Emerging Markets Equity Index Fund (the “Emerging Markets Fund”) after the Emerging Markets Fund liquidates its portfolio, and as a
      result, the Fusion Funds will each indirectly bear its pro rata share of the transaction costs involved in liquidating the Emerging Markets Fund’s portfolio.
      Similarly, the Fusion Funds will redeem the