Deloitte & Touche LLP – ‘40-17F2’ on 3/3/21 re: Ivy Variable Insurance Portfolios

On:  Wednesday, 3/3/21, at 6:49pm ET   ·   As of:  3/4/21   ·   Effective:  3/4/21   ·   Accession #:  1050269-21-9   ·   File #:  811-05017

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Certificate of Accounting of Securities in the Custody of an Investment Company   —   Form N-17f-2   —   Rule 17f-2   —   ICA’40
Filing Table of Contents

Document/Exhibit                   Description                      Pages   Size 

 1: 40-17F2     Certificate of Accounting of Securities in the         4±    17K 
                Custody of an Investment Company                                 


UNITED STATES                                                                   
SECURITIES AND EXCHANGE COMMISSION                                              
Washington, D.C.  20549                                                         
                           -----------------
------------                                                                    
FORM N-17f-2                                        OMB                         
Approval                                                                        
                           -----------------
------------                                                                    
Certificate of Accounting of Securities and                                     
Similar Investments in the Custody of                                           
Management Investment Companies                                                 

Pursuant to Rule 17f-2 [17 CFR 270.17f-2]                                       

OMB Number: 3235-0360                                                           
Expires: March 31, 2021                                                         

Estimate average burden                                                         
hours per response  2.00                                                        

--------------------------------------------------------------                  
---------------                                                                 
1. Investment Company Act File Number:        Date examination                  
completed:                                                                      

811-05017                                    December 31, 2020                  

--------------------------------------------------------------                  
---------------                                                                 

2. State Identification Number:                                                 

AL             AK             AZ             AR             CA                  
CO                                                                              
CT             DE             DC             FL             GA                  
HI                                                                              
ID             IL             IN             IA             KS                  
KY                                                                              
LA             ME             MD             MA             MI                  
MN                                                                              
MS             MO             MT             NE             NV                  
NH                                                                              
NJ             NM             NY             NC             ND                  
OH                                                                              
OK             OR             PA             RI             SC                  
SD                                                                              
TN             TX             UT             VT             VA                  
WA                                                                              
WV             WI             WY             PUERTO RICO                        
Other (specify):                                                                

--------------------------------------------------------------                  
---------------                                                                 

3. Exact name of investment company as specified in                             
registration statement:                                                         

Ivy Variable Insurance Portfolios                                               
--------------------------------------------------------------                  
---------------                                                                 

4. Address of principal executive office (number, street,                       
city, state, zip code):                                                         

6300 Lamar Avenue, Overland Park, KS 66201                                      
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---------------                                                                 

March 2, 2021                                                                   

United States Securities and Exchange Commission                                
Office of Applications and Report Services                                      
450 Fifth Street                                                                
N.W. Washington, DC 20549                                                       

Dear Sirs:                                                                      

Enclosed is a copy of Form N-17f-2, along with our related                      
report, dated March 2, 2021, on our examination of the                          
investment portfolios of Ivy VIP Pathfinder Aggressive, Ivy VIP                 
Pathfinder Conservative, Ivy VIP Pathfinder Moderate, Ivy VIP                   
Pathfinder Moderately Aggressive, Ivy VIP Pathfinder Moderately                 
Conservative, Ivy VIP Pathfinder Moderate - Managed Volatility,                 
Ivy VIP Pathfinder Moderately Aggressive - Managed Volatility,                  
and Ivy VIP Pathfinder Moderately Conservative - Managed                        
Volatility, eight of the series comprising Ivy Variable                         
Insurance Portfolios, as of the close of business on December                   
31, 2020.                                                                       

Very truly yours,                                                               

/s/ Rajan D. Chari                                                              

Rajan Chari                                                                     
Partner                                                                         

INDEPENDENT ACCOUNTANTS' REPORT                                                 

To the Board of Trustees of Ivy Variable Insurance Portfolios:                  

We have examined management's assertion, included in the                        
accompanying Management Statement Regarding Compliance with                     
Certain Provisions of the Investment Company Act of 1940, that                  
Ivy VIP Pathfinder Aggressive, Ivy VIP Pathfinder Conservative,                 
Ivy VIP Pathfinder Moderate, Ivy VIP Pathfinder Moderately                      
Aggressive, Ivy VIP Pathfinder Moderately Conservative, Ivy VIP                 
Pathfinder Moderate - Managed Volatility, Ivy VIP Pathfinder                    
Moderately Aggressive - Managed Volatility, and Ivy VIP                         
Pathfinder Moderately Conservative - Managed Volatility, eight                  
of the series comprising Ivy Variable Insurance Portfolios (the                 
"Funds"), maintain certain of their securities in uncertificated                
shares of mutual funds affiliated with the Funds and are held                   
with Waddell & Reed Services Company (WRSCO), a registered                      
transfer agent under Section 17A of the Securities Exchange Act                 
of 1934 (the "specified requirements"), as of December 31, 2020.                
The Funds' management is responsible for its assertion. Our                     
responsibility is to express an opinion on management's                         
assertion about the Funds' compliance with the specified                        
requirements based on our examination.                                          

Our examination was conducted in accordance with attestation                    
standards established by the American Institute of Certified                    
Public Accountants. Those standards require that we plan and                    
perform the examination to obtain reasonable assurance about                    
whether management's assertion about compliance with the                        
specified requirements is fairly stated, in all material                        
respects. An examination involves performing procedures to                      
obtain evidence about management's assertion. The nature,                       
timing, and extent of the procedures selected depend on our                     
judgement, including an assessment of the risks of material                     
misstatement of management's assertion, whether due to fraud or                 
error. We believe that the evidence we obtained is sufficient                   
and appropriate to provide a reasonable basis for our opinion.                  

Included among our procedures were the following tests performed                
as of December 31, 2020, and with respect to agreement of                       
security purchases and sales, for the period from August 31,                    
2020 (the date of our last examination) through December 31,                    
2020:                                                                           

*Confirmation of all securities held with the sub-transfer agent                
*Reconciliation of all such securities to the books and records                 
of the Funds and sub-transfer agent                                             
*Agreement of 10 security purchases and 10 security sales from                  
the books and records of the Funds to the transfer record report                
of the sub-transfer agent and the cash records of the custodian.                

Our examination does not provide a legal determination on the                   
Funds' compliance with specified requirements.                                  

In our opinion, management's assertion that the Funds maintain                  
certain of their securities in uncertificated shares of mutual                  
funds affiliated with the Funds and are held with Waddell & Reed                
Services Company as of December 31, 2020, with respect to                       
securities reflected in the investment account of the Funds, is                 
fairly stated, in all material respects.                                        

This report is intended solely for the information and use of                   
management and the Board of Trustees of Ivy Variable Insurance                  
Portfolios and the U.S. Securities and Exchange Commission and                  
is not intended to be, and should not be, used by anyone other                  
than the specified parties.                                                     

/s/ DELOITTE & TOUCHE LLP                                                       

Kansas City, Missouri                                                           
March 2, 2021                                                                   

Management Statement Regarding Compliance with Certain                          
Provisions of the Investment Company Act of 1940                                

The Ivy VIP Pathfinder Aggressive, Ivy VIP Pathfinder                           
Conservative, Ivy VIP Pathfinder Moderate, Ivy VIP Pathfinder                   
Moderately Aggressive, Ivy VIP Pathfinder Moderately                            
Conservative, Ivy VIP Pathfinder Moderate - Managed Volatility,                 
Ivy VIP Pathfinder Moderately Aggressive - Managed Volatility,                  
and Ivy VIP Pathfinder Moderately Conservative - Managed                        
Volatility (the "Funds"), eight of the series comprising Ivy                    
Variable Insurance Portfolios, are organized as fund of funds                   
with uncertificated shares recorded within the books and records                
of the investment adviser's affiliated transfer agent. As such,                 
the Funds are applying requirements set forth in the Franklin                   
Investors Securities Trust No Action Letter (dated September 24,                
1992) ("No Action Letter") in lieu of strict compliance with                    
subsections (b) and (c) of Rule 17f-2, "Custody of Investments                  
by Registered Management Investment Companies," of the                          
Investment Company Act of 1940. The Funds have agreed to treat                  
Waddell & Reed Services Company ("WRSCO") as a limited purpose                  
securities depository for purpose of holding these                              
uncertificated shares. The Funds buy and sell shares of                         
underlying Ivy Variable Insurance Portfolios ("Ivy VIP Funds").                 

We are responsible for establishing and maintaining effective                   
internal controls over applying the requirements set forth in                   
the No Action Letter. Based on this evaluation, we assert that                  
the Funds maintained the uncertificated shares of Ivy VIP Funds                 
with WRSCO, a registered transfer agent under Section 17A of the                
Securities Exchange Act of 1934, as of December 31, 2020, and                   
for the period from August 31, 2020 (last examination date)                     
through December 31, 2020, with respect to securities reflected                 
in the investment accounts of the Funds.                                        

Ivy Variable Insurance Portfolios                                               

By:                                                                             
/s/ Philip J. Sanders                                                           
Philip J. Sanders, President                                                    

By:                                                                             
/s/ Joseph W. Kauten                                                            
Joseph W. Kauten, Senior Vice President & Treasurer                             

Dates Referenced Herein   and   Documents Incorporated by Reference

This ‘40-17F2’ Filing		Date		Other Filings
		3/31/21		N-MFP2,  NPORT-P,  NPORT-P/A
Filed as of / Effective on:		3/4/21		40-17F2,  N-MFP2
Filed on:		3/3/21		40-17F2
		3/2/21
		12/31/20		24F-2NT,  N-CEN,  N-CSR,  N-MFP2,  NPORT-P
		8/31/20		N-MFP2,  N-PX
		9/24/92
				List all Filings