SEC Company Response from EQ PREMIER VIP TRUST (CIK 0001160168) — Aug 7, 2020
EQ PREMIER VIP TRUST (CIK 0001160168)
Date: Aug. 7, 2020 · CIK: 0001160168 · Accession: 0001193125-20-212876
AI Filing Summary & Sentiment
File numbers found in text: 333-70754, 811-10509
Letter
VIA EDGAR AND E-MAIL Division of Investment Management 100 F Street, NE Washington, DC 20549 Re: Sarbanes-Oxley Review of the Annual Report for the Period Ended 12/31/19 on Form N-CSR of EQ Premier VIP Trust (File Nos. 333-70754; 811-10509)
Dear Mr. Fox:
On behalf of EQ Premier VIP Trust (formerly known as AXA Premier VIP Trust) (the “Trust”), set forth below is the comment you provided on August 3, 2020, regarding the SEC Staff’s recent review of the Trust’s Annual Report on Form N-CSR for the fiscal year ended December 31, 2019. Your comment is set forth in italics and is followed by the Trust’s response. Unless otherwise noted, defined terms have the same meanings as in the Annual Report.
Comment: In the Form N-CEN for the period ended December 31, 2019, filed on March 13, 2020, the Trust reported on Item B.13 that there were claims filed under the directors and officers/errors and omissions insurance policy during the reporting period with respect to the Trust. Please describe the details regarding these claims. Please also explain whether the Trust considered if any financial statement disclosure was necessary in connection with the claims in the Annual Report for the period ended December 31, 2019.
Response: The Trust confirms that no claims were filed under the directors and officers/errors and omissions insurance policy during the reporting period with respect to the Trust. The Trust reported “Yes” in error. The Trust does not consider this error to be material and will provide a correct response in future Form N-CEN filings.
* * * * *
K&L GATES LLP
1601 K STREET NW WASHINGTON DC 20006
T +1 202 778 9000 F +1 202 778 9100 klgates.com
U.S. Securities and Exchange Commission
August 7, 2020
Page 2
If you have any questions or comments regarding the foregoing, please contact me at (202) 778-9351 or my colleague Fatima Sulaiman at (202) 778-9082.
Sincerely,
/s/ Mark C.
Amorosi
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CORRESP
August 7, 2020
VIA EDGAR AND E-MAIL
Mark C Amorosi
mark.amorosi@klgates.com
T +1 202 778 9351
F +1 202 778 9100
Mr. Jason Fox
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Re:
Sarbanes-Oxley Review of the Annual Report for the Period Ended 12/31/19 on Form
N-CSR of EQ Premier VIP Trust (File Nos. 333-70754; 811-10509)
Dear Mr. Fox:
On behalf of EQ Premier VIP Trust (formerly known as AXA Premier VIP Trust) (the “Trust”), set forth below is the comment you
provided on August 3, 2020, regarding the SEC Staff’s recent review of the Trust’s Annual Report on Form N-CSR for the fiscal year ended December 31, 2019. Your comment is set forth in
italics and is followed by the Trust’s response. Unless otherwise noted, defined terms have the same meanings as in the Annual Report.
Comment: In the Form N-CEN for the period ended December 31, 2019, filed
on March 13, 2020, the Trust reported on Item B.13 that there were claims filed under the directors and officers/errors and omissions insurance policy during the reporting period with respect to the
Trust. Please describe the details regarding these claims. Please also explain whether the Trust considered if any financial statement disclosure was necessary in connection with the claims in the Annual Report
for the period ended December 31, 2019.
Response: The Trust confirms that no claims were filed under the directors
and officers/errors and omissions insurance policy during the reporting period with respect to the Trust. The Trust reported “Yes” in error. The Trust does not consider this error to be material and will provide a correct response in
future Form N-CEN filings.
* * *
* *
K&L GATES LLP
1601 K STREET NW WASHINGTON DC 20006
T +1 202 778 9000 F +1 202
778 9100 klgates.com
U.S. Securities and Exchange Commission
August 7, 2020
Page 2
If you have any questions or comments regarding the foregoing, please contact me at (202) 778-9351 or my colleague Fatima Sulaiman at (202) 778-9082.
Sincerely,
/s/ Mark C.
Amorosi
cc:
William MacGregor, Esq.
Maureen Kane, Esq.
Victoria Zozulya, Esq.
Equitable Investment Management Group, LLC
Fatima Sulaiman, Esq.
K&L Gates LLP