|
|
One International Place, 40th Floor |
|
100 Oliver Street | |
|
Boston, MA 02110-2605 | |
|
+1 617 728 7100 Main | |
|
+1 617 426 6567 Fax | |
|
|
www.dechert.com |
|
|
|
|
|
KAITLIN MCGRATH |
|
|
|
|
|
kaitlin.mcgrath@dechert.com |
|
|
+1 617 728 7116 Direct |
|
|
+1 617 275 8395 Fax |
July 12, 2017
Kenneth Ellington
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Re: Forethought Variable Insurance Trust (the “Registrant”) (SEC File Nos. 333-189870 and 811-22865)
Dear Mr. Ellington:
This letter responds to a comment provided in a July 10, 2017 telephone conference with respect to a Correspondence filing made by the Registrant on June 30, 2017, which pertained to the Registrant’s annual report for the period ended December 31, 2016 filed with the Registrant’s Form N-CSR (Accession No. 0001580642-17-001400) on March 3, 2017. A summary of the comment, and the Registrant’s response thereto, is provided below.
|
1. |
Comment: |
With respect to the Registrant’s response to Comment 14, please refer to paragraph 5.62 of the AICPA Audit and Accounting Guide for Investment Companies. In light of the fact that certain of the Portfolios appear to be “funds of funds,” please include a general description of the “funds of funds” structure in Note 1 — Organization of the Notes to Financial Statements. |
|
|
|
|
|
|
Response: |
The requested disclosure will be added to future filings. |