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CORRESP

ROPES & GRAY LLP

PRUDENTIAL TOWER

800 BOYLSTON STREET

BOSTON, MA 02199-3600

WWW.ROPESGRAY.COM

January 27, 2020

Angela Jaimes

 617-951-7591

angela.jaimes@ropesgray.com

 BY EDGAR

Securities and Exchange Commission

 100 F Street, N.E.

Washington, D.C. 20549

Re:
 Premier Multi-Series VIT (File Nos. 333-182079, 811-22712) Responses to Comments on RCM Dynamic Multi-Asset Plus VIT Portfolio Preliminary Proxy Statement

Dear Mr. Scott:

 On January 7, 2020,
Premier Multi-Series VIT (the “Trust”) filed a preliminary proxy statement pursuant to Rule 14-6(a) under the Securities Exchange Act of 1934. The proxy statement relates to the proposed
plan to liquidate the RCM Dynamic Multi-Asset Plus VIT Portfolio, a series of the Trust (the “Portfolio”), on or about April 24, 2020. On January 16, 2020, you provided us orally with the comments of the staff (the
“Staff”) of the Securities and Exchange Commission (the “Commission”) on the preliminary proxy statement. Summaries of your comments and the Trust’s responses are set forth below.

1.
 Comment: Please confirm supplementally whether the Portfolio is an affiliate of Allianz Life Insurance
Company of North America or Allianz Life Insurance Company of New York.

 Response: Allianz Life Insurance Company
of North America and Allianz Life Insurance Company of New York (together, “Allianz Life”) and Allianz Global Investors U.S. LLC (“AllianzGI U.S.”), the investment manager to the Portfolio, are both wholly-owned indirect
subsidiaries of Allianz SE. The Trust respectfully highlights that Allianz Life and AllianzGI U.S. do not coordinate in management of the Portfolio.

2.
 Comment: Please confirm that the Portfolio will stay current on all filing obligations until liquidation
is consummated.

 Response: The Trust confirms that the Portfolio intends and expects to stay current on all filing
obligations until liquidation is consummated.

3.
 Comment: Once liquidation is consummated, please ensure that the series/class identifiers on the EDGAR
system are marked as “inactive.”

 Response: The Trust undertakes to make the requested changes on the
EDGAR system.

January 27, 2020

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4.
 Comment: Please confirm that the Trust will use reasonable efforts to locate all shareholders of the
Portfolio and all owners of contracts with value allocated to the Portfolio through a separate account.

 Response:
The Trust confirms that, in connection with the distribution of proxy materials, it will use reasonable efforts to locate all shareholders of the Portfolio and all owners of contracts with value allocated to the Portfolio through a separate account.

5.
 Comment: Please confirm that the Trust will decide on the collectability of the Portfolio’s
receivables and will include in the costs of liquidation any receivables it believes will not be collected.

Response: The Trust notes that receivables that are expected to settle post liquidation will be funded by AllianzGI U.S. so that there
is not expected to be any write-down to the Portfolio’s net asset value.

6.
 Comment: Please include an estimate of the liquidation costs and approximate solicitation costs.

 Response: In response to this comment, the above-referenced disclosure will be revised as follows (new language
denoted by underline):

 Q&A: The liquidation proceeds will be net of expenses associated with the Liquidation (however, Allianz Global
Investors U.S. LLC, the investment manager of the Portfolio, will bear the full cost of this proxy solicitation). The expenses associated with the Liquidation will consist primarily of out-of-pocket transaction costs associated with liquidating the Portfolio’s investment portfolio, which costs, given the relatively liquid market for the securities in the Portfolio’s investment
portfolio, are currently not expected by Allianz Global Investors U.S. LLC to exceed $4,500, although market factors cannot be predicted.

Proxy Statement: The Portfolio will not bear the cost of this proxy solicitation, which is expected to be approximately $5,000. Allianz
Global Investors U.S. LLC, the investment manager of the Portfolio, will bear the full cost of this proxy solicitation. The Portfolio will, however, bear the other expenses associated with the Portfolio’s liquidation, including
the. These expenses borne by the Portfolio will consist primarily of out-of-pocket transaction costs associated with liquidating
itsthe Portfolio’s investment portfolio., which costs, given the relatively liquid market for the securities in the Portfolio’s investment portfolio, are currently not expected by Allianz Global
Investors U.S. LLC to exceed $4,500, although market factors cannot be predicted. The actual amounts to be received by Contract Owners who do not transfer Contract value before the liquidation are subject to significant uncertainties and
are not possible to predict at this time.

January 27, 2020

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7.
 Comment: Please confirm that Financial Accounting Standards Board FAS5 and Accounting Standards
Codification 450 will be used in accounting for the liquidation, i.e., that the Portfolio has set aside an appropriate amount of assets to cover its liabilities.

Response: The Portfolio is not required to perform an accounting on a liquidation basis in connection with the liquidation. As of
the last financial statement date of December 31, 2019, there were no known contingencies for which to accrue related to the liquidation. All current liabilities of the Portfolio can be covered by the Portfolio’s current assets.

8.
 Comment: Please confirm supplementally if shares of the Portfolio are still being offered to other
Allianz segregated asset accounts (“Separate Accounts”).

 Response: Allianz Life has indicated that the
Portfolio is not actively being marketed, although contract holders if they choose, can invest in the Portfolio. The Portfolio will cease accepting new investments as soon as practicable given the operational considerations of Allianz Life which may
be up until the Portfolio’s liquidation is consummated. A prospectus supplement announcing the closing and liquidation of the Portfolio and termination of the Trust was filed on December 18, 2019.

9.
 Comment: Please confirm that the substitution will be done consistent with the Northwestern National
Life Ins. Co. line of no action letters and that all conditions of those letters will be complied with. In that regard, please confirm that contract owners have received notice of their substitution in the form of a supplement to the current
prospectus which outlines their surrender rights and rights to transfer their accumulating values from the liquidating funds to other funding options under their contracts without incurring any transfer or other charges as provided in the
Northwestern letters. Also, please confirm that after the substitution, all contract owners who have values transferred to a substitute fund will be notified that they have the same surrender and free transfer rights for another 90 days.

 Response: The Trust notes that it previously liquidated the NFJ Dividend Value Portfolio, a series of the Trust,
in the spring of 2018. The Trust confirms that it is following the same procedures that were previously discussed and confirmed with the Staff at that time.

The Trust notes that letters from the insurance company sponsors that will accompany the mailing of the definitive proxy statement to contract
owners will provide notice of the substitution and outline surrender rights and rights to transfer accumulating values from the liquidating fund to other funding options under the contracts without incurring any transfer

January 27, 2020

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or other charges. The Trust also notes that contract owners who have values transferred will receive an additional notice shortly following the substitution reminding them that they have the same
surrender and free transfer rights. Finally, the Trust confirms supplementally that all contract owners who have values transferred to a substitute fund will be notified that they have the same surrender and free transfer rights for 90 days after
the substitution.

10.
 Comment: Please disclose if transfer fees will be waived as part of the transaction.

 Response: Transfer fees related to the liquidation will be waived for up to 60 days after the liquidation. The
Trust notes that information about free transfer rights associated with the transaction is specified in letters from the insurance company sponsors that will accompany the mailing of the definitive proxy statement to contract owners. Because these
letters from the insurance company sponsors will accompany the definitive proxy statement, the Trust will file them on the EDGAR system as definitive additional materials. The letters to contract owners are included in Appendix A.

11.
 Comment: Please provide information about the types of investment options the contract values will be
distributed to.

 Response: The Trust notes that information about the fund into which the contract value allocated
to the Portfolio of contract owners who do not provide transfer instructions prior to liquidation will be transferred is specified in letters from the insurance company sponsors that will accompany the mailing of the definitive proxy statement and
that the summary prospectus of the fund will be attached to these letters. The summary prospectus of the substituted fund will also be filed on EDGAR as definitive additional materials and is included in Appendix B.

12.
 Comment: Please confirm supplementally whether there is state law or a governing document that requires
a shareholder vote for liquidation, because the 1940 Act does not. Please state, if deemed appropriate for disclosure in this forum, what outcomes will result if the liquidation is not approved.

Response: Article IX, Section 4 of the Trust’s Amended and Restated Agreement and Declaration of Trust (the
“Declaration of Trust”) provides that the Portfolio may be terminated by the Trust’s Board of Trustees by written notice to shareholders. The Declaration of Trust does not require shareholder approval for termination of the
Portfolio. However, the insurance company separate accounts investing in the Portfolio are “unit investment trusts” as defined in the 1940 Act. Section 26(c) of the 1940 Act requires that the sponsor of a unit investment trust holding
the securities of a single issuer cannot substitute another security for that security without the approval of the Commission. The Staff has granted no-action relief from the requirement to seek an approval
order under

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Section 26(c) of the 1940 Act. Here, because Allianz Life is a corporate affiliate of the investment adviser to the Portfolio, the specific form of
no-action relief is Northwestern National Life Ins. Co., pub. avail. Apr. 10, 1995, which granted relief from the necessity of seeking the approval of the Commission for the substitution of securities
in circumstances where contract owners would have the opportunity to vote on the transactions that resulted in the substitution. Allianz Life Insurance Company of North America and Allianz Life Insurance Company of New York have informed the Trust
that they believe they may rely on Northwestern, provided that the liquidation of the Portfolio is approved by shareholders in the manner reflected in the Trust’s intended filings, and for this reason the Trust’s Board of Trustees
is seeking shareholder approval of the plan of liquidation.

 If the liquidation of the Portfolio is not approved by the shareholders, the
Portfolio will continue to operate as a series of the Trust, with the same investment objectives as in the past, while the Board of Trustees considers whether another course of action would benefit the Portfolio, its shareholders and the contract
owners. At this time, it is unknown what alternative courses of actions might be considered or approved by the Board of Trustees.

13.
 Comment: Please confirm whether the Portfolio will pay for the proxy solicitation. Additionally, remove
the sentence clarifying responsibility for the cost of proxy solicitation on the third page of the “Question and Answer” subsection.

Response: The Trust confirms supplementally that the Portfolio will not bear the cost of the proxy solicitation and that Allianz Global
Investors U.S. LLC, the investment manager of the Portfolio, will bear the full cost. In light of this fact, the Trust respectfully declines to remove the below sentence in relation to the cost of proxy solicitation as it believes the sentence
provides helpful information to shareholders.

 Allianz Global Investors U.S. LLC, the investment manager of the Portfolio, will bear the
full cost of this proxy solicitation.

14.
 Comment: Please remove the excess parenthetical bracket in the “Question and Answer”
subsection.

 Response: The Trust confirms that this change will be made in the definitive proxy statement.

15.
 Comment: In “Board Considerations in Approving the Proposed Liquidation,” please consider
adding more on why the Trust thinks the Portfolio may not be viable on a continuing basis.

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 Response: In response to this comment, the disclosure below will be incorporated into
the “Board Considerations in Approving the Proposed Liquidation” section of the proxy statement:

 After analysis and discussion,
AllianzGI U.S. presented to the Board its belief that the ongoing viability of the Portfolio is uncertain in light of its current asset level and that the Portfolio is unlikely to experience significant asset growth in the foreseeable future.
AllianzGI U.S. does not have an optimistic outlook for the Portfolio to attract or gain scale given its small size, limited client interest, and challenged performance profile. Allianz Life has been the only insurance company investor in the
Portfolio since inception and AllianzGI U.S. believes that Allianz Life has limited interest in portfolios of this type managed by 3rd parties. In addition, there are no other portfolios in the Trust and no current prospects for future portfolios
requiring our maintaining the Trust.

17.
 Comment: Please clarify whether the “Effective Date” of April 24, 2020, stated under the
section heading “Summary of the Plan,” is the liquidation date of the Portfolio.

 Response: The Trust
confirms that the Portfolio will be liquidated and dissolved as soon as practicable after the effective date of the plan of liquidation, termination and dissolution. For clarity, the above-referenced disclosure will be revised as follows (new
language denoted by underline):

 Effective Date and Cessation of Business: Pending the requisite approval by the Portfolio’s
shareholders, the Plan shall become effective at the close of business on or about April 24, 2020 (the “Effective Date”), or such other date as may be determined by the President of the Trust (the “Effective
Date”), and the Portfolio will be liquidated and dissolved as promptly as practicable after the Effective Date.

 The Trust notes,
in addition, that the current disclosure in the “Dissolution” subsection under the “Summary of Plan” section already includes the following language:

Dissolution. As promptly as practicable after the Effective Date, the Portfolio will be liquidated and dissolved and thereupon be deemed
abolished and its designation as a series of the Trust no longer established.

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Should you have any questions, please do not hesitate to call me at (617) 951-7591. Thank you for your assistance.

January 27, 2020

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Very truly yours,

 /s/ Angela C. Jaimes

Angela C. Jaimes, Esq.

cc:
 Craig Ruckman, Esq.

George B. Raine, Esq.

 Appendix A

 Allianz Life Insurance Company of New York

January 28, 2020

 Dear Allianz Life Insurance Company of
New York contract owner:

 We are sending you this notice about the proposed liquidation of RCM Dynamic Multi-Asset Pl