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Stradley Ronon Stevens & Young, LLP
2005 Market Street, Suite 2600
Philadelphia, PA 19103
215.564.8000
www.stradley.com
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Jonathan M. Kopcsik
(215) 564-8099
jkopcsik@stradley.com
July 29, 2022
VIA EDGAR
John Grzeskiewicz
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549-9303
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Re:
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Ivy Variable Insurance Portfolios (the “Registrant”)
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File Nos. 033-11466; 811-05017
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Dear Mr. Grzeskiewicz:
On behalf of the Registrant, below are its responses to the comments you provided us on July 6, 2022 with regard to its Post-Effective Amendment No. 87 (the “Post-Effective
Amendment”) to its Registration Statement on Form N-1A relating to certain changes to the Delaware VIP Global Value Equity (formerly, Delaware Ivy VIP Global Equity Income) (the “Fund”). The Post-Effective Amendment was filed with the U.S.
Securities and Exchange Commission (“Commission”) on May 27, 2022.
Below we have provided your comments and the Registrant’s responses to them.
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1.
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Comment: Provide completed fee table and expense example numbers for the Fund at least one week prior to the effective date of the Post-Effective Amendment.
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Response: Please Exhibit A for the requested information.
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Comment: Confirm that the Fund’s manager, Delaware Management Company, is not waiving any fees or reimbursing expenses for the Fund.
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Response: The Registrant so confirms.
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* * *
Please direct any questions or comments relating to this filing to me at the above-referenced telephone number.
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Very truly yours,
/s/Jonathan M. Kopcsik
Jonathan M. Kopcsik
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cc:
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Kathryn Williams
Macquarie Asset Management
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EXHIBIT A
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Annual portfolio operating expenses (expenses that you pay each year as a percentage of the value of your investment)
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Class
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II
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Management fees
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0.70%
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Distribution and service (12b-1) fees
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0.25%
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Other expenses
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0.06%
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Total annual fund operating expenses
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1.01%
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Class
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II
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1 Year
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$103
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3 Years
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$322
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5 Years
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$558
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10 Years
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$1,236
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