Aim Variable Insurance Funds CORRESPCorrespondence with SEC

Response: We are currently in the process of re-evaluating the format and content of the Management’s Discussion of Fund Performance section in our Funds’ annual reports, and will consider accordingly. With respect to the Fund prospectuses, to the extent risks are not already disclosed in order of importance, we will consider accordingly, in connection with recent Staff guidance and comments, disclosing each Fund’s risks in order of importance, as opposed to alphabetical order.

Response: We consider the materiality of the individual components that make up the amounts payable to affiliates when determining whether to break them out individually and will continue to do so going forward.  We believe this complies with GAAP.

Response: Invesco currently does not include the investments in affiliates disclosure required by Rule 12-14 of Regulation S-X for a Fund’s investments in affiliated money market funds in the Fund’s Notes to Financial Statements based on statements in 2008 by Staff members to an AICPA Expert Panel that the Staff has not objected to the omission of disclosure required by Rule 12-14 of Regulation S-X for investments in affiliated money market funds. [ Invesco believes that omission of such disclosure is appropriate because Invesco views investments in affiliated money market funds as cash equivalents due to their the highly liquid, low risk nature.  Invesco further believes that the information required by Rule 12-14, including net realized gain or loss  and net increase or decrease in unrealized appreciation or depreciation, are not informative data points for money market funds that operate pursuant to Rule 2a-7.

Response: Footnote (d) in the Financial Highlights table explains that “Effective July 26, 2018, the Fund modified certain investment policies utilized in achieving its investment objective throughout the period. The Fund’s net investment income, ratio of net investment income and portfolio turnover have increased significantly due to the realignment of the Fund’s portfolio of investments as a result of these changes.” In accordance with Item 16(e) of Form N-1A, this explanation will also be included in the Fund’s Statement of Additional Information when it updates in June 2020 pursuant to Rule 485(b).

Response: The Trusts’ confirm that their policy is to segregate liquid assets in an amount equal to the face value of the floating-rate securities that a Fund may be required to repurchase from a TOB Trust. The amount segregated is disclosed as a footnote to the Schedule of Investments.

Response: Rule 12-12 of Regulation S-X states “For variable rate securities, indicate a description of the reference rate and spread and: (1) The end of period interest rate or (2) disclose the end of period reference rate for each reference rate described in the Schedule in a note to the Schedule.” Our current presentation reflects option 1 referenced in Rule 12-12 above.  The Schedule of Investments discloses the variable rate + spread and the end of period interest rate for variable rate securities in the security description.

Response: Both the payment-in-kind and cash rates are currently disclosed in the Schedule of Investments.  For securities where there is only a payment-in-kind rate disclosed, those securities did not have a cash rate on the reporting date.

Response: This information was not disclosed because the Fund had no borrowings during the reporting period.

Response:  The Fund will disclose the reason for the variation, in accordance with 16(e), in its Statement of Additional Information, which will become effective on or about February 28, 2020 pursuant to Rule 485(b).

Response: The Fund’s future shareholder reports and prospectuses will be modified to reflect that the S&P 500® Index is the Fund’s broad-based securities market index.

Response: The percentages provided are based on the notional value of each underlying component.  Going forward, the disclosure regarding reference entity components will be enhanced to explain the basis of the underlying components. Enhancing the disclosure of the description of the underlying components is under consideration.

Response: The Invesco Energy Fund is a diversified fund and thus operates, and intends to continue to operate, as such.  For this reason, the Fund does not include non-diversification risk disclosure in the Fund’s prospectus.

The Fund acknowledges that at the end of fiscal year April 30, 2019, more than 25% of the assets of Invesco Energy Fund were comprised of individual holdings that each represented more than 5% of the Fund’s total assets (each, a “greater than 5% position”) as a result of changes in the market value of such greater than 5% positions (and other securities held by the Fund) and not as a result of purchases of such greater than 5% positions.  We confirm that the Fund continues to comply with the diversification requirements of Sections 5(b) and 5(c) of the Investment Company Act of 1940.

We note that while “non-diversification risk” disclosure is not included in the Invesco Energy Fund’s prospectus or annual report, “energy sector risk” disclosure (with respect to concentrating in the energy sector) is included.

Response: The Notes to the Financial Statements in the shareholder reports include the following sample disclosure:

“Invesco Liquid Assets Portfolio, Invesco STIC Prime Portfolio and Invesco Tax-Free Cash Reserve Portfolio may impose a fee upon the sale of shares or may temporarily suspend the ability to sell shares if the Fund’s liquidity falls below required minimums or because of market conditions or other factors. The Board of Trustees has elected not to subject Invesco Treasury Portfolio, Invesco Government & Agency Portfolio and Invesco Treasury Obligations Portfolio to liquidity fee and redemption gate requirements at this time, as permitted by Rule 2a-7.” The Registrant will consider enhancing the disclosure to add additional detail regarding the circumstances under which a liquidity fee or redemption gate will be imposed.