Aim Variable Insurance Funds CORRESPCorrespondence with SEC

The Registrant believes the Bloomberg U.S. Aggregate Bond Index is an appropriate broad-based securities market index for the Invesco Peak Retirement 2025 Fund, Invesco Peak Retirement 2030 Fund, Invesco Peak Retirement 2035 Fund and Invesco Peak Retirement 2040 Fund (herein, the “Funds”) for purposes of comparing performance.  Form N-1A defines an appropriate broad-based securities market index as one administered by an organization that is not an affiliated person of the fund, its investment adviser, or principal underwriter, unless the index is widely recognized and used.¹ The Commission has described such an index as “one that provides investors with a performance indicator of the overall applicable stock or bond markets, as applicable,” while also stating that a fund would have “considerable flexibility in selecting a broad-based index that it believes best reflects the market(s) in which it invests.”²  The Registrant believes the Bloomberg U.S Aggregate Bond Index meets the Form N-1A definition and is also one that provides investors in the Funds with a performance indicator of a relevant overall market.  The Funds are designed for investors expecting to retire in each Fund’s respective specified year in its name and/or begin to withdraw their retirement assets around that year.  While each Fund had exposure to more than 50% in underlying equity funds as of the most recent fiscal year end, each Fund’s portfolio also had significant exposure to non-equity funds, i.e., significantly in fixed income, as well as alternative and/or money market funds.  Each Fund’s principal investment strategy indicates in its prospectus that the Fund “follows a glide path that adjusts the combination of underlying funds to generally become more conservative over time, until the Fund reaches its destination point, which is approximately 15 years after the target retirement date stated in the Fund’s name.”  As investors’ appetite for risk tends to decline as they get closer to their specified target retirement date for these Funds – and the Funds’ portfolios gradually become more conservative - the Registrant believes it is reasonable to compare the Funds’ performance against a benchmark that represents the more conservative U.S. investment-grade, fixed income market.

The Registrant notes that, as of December 31, 2021, a majority of the Fund’s portfolio, specifically $1,047,730,846, was comprised of securities that were determined to be Level 2 per the GAAP hierarchy.  The convertible securities held by the Fund were assigned as Level 2 due to the prices being determined using other significant observable inputs.  The Level 1 securities held by the Fund were primarily preferred stocks and money market funds which are listed on an exchange and the quoted prices are readily available. The Registrant has reviewed the language in Note 1 to the Financial Statements and will remove the parenthetical exception-based reference regarding convertible securities going forward.

Zero coupon convertible bonds do not accrue interest but do amortize and/or accrete premiums and discounts until call/conversion date. Upon conversion date, a new cusip and holding will be received by the Fund at which time it will be accounted for as an equity instrument.

This was the result of a special dividend paid by Constellation Software Inc. in the form of a dividend-in-kind of subordinate voting shares of Topicus.com for each common share of Constellation Software Inc. held on December 28, 2020 in connection with the acquisition by Constellation Software Inc. of 100% of the shares of Topicus.com.

The Registrants believe that the shareholder reports comply with Accounting Standards Codification No. 815 (Derivatives and Hedging) requirements of disclosure and that the current disclosure provides sufficient information to shareholders. The Registrants believe that including additional data points in the already lengthy disclosure may be confusing to shareholders, and therefore respectfully decline to make the change at this time.

These are “Preference Shares” awarded by Zee to equity shareholders as a bonus at no cost to the equity shareholders and not purchased in the open

market, hence zero cost.  The security is valued as Level 1 because the security was readily available and priced on the Bombay Stock Exchange (BSE).

The Registrants believe that the current disclosure complies with applicable requirements and provides sufficient information to shareholders. The Registrants fully consolidate the Subsidiary financial statements with the Fund’s financial statements and believe that including additional information about the Subsidiary may be confusing to shareholders, and therefore respectfully decline to make the change at this time.

The Registrants confirm that ELNs currently reference the issuer and not the underlying reference asset in the shareholder reports.  For future shareholder reports, the underlying reference asset will be included in the ELN security description on the Schedule of Investments.

The Registrants confirm that risk disclosure regarding Chinese VIEs was added to all Funds with exposure to China.  For some Funds, the disclosure was incorporated into a Fund’s registration statement during its annual update as the timing of the supplement coincided with such Funds’ annual updates.

On April 24, 2020, S&P rebalanced the S&P 500 Equal Weight Index (the “S&P 500 EW Index”); such rebalancing had previously been scheduled for March 31, 2020 but was postponed due to market volatility and other circumstances surrounding the coronavirus pandemic.  The Fund’s portfolio managers did not realize the S&P 500 EW Index was rebalanced until April 29, 2020, at which time they promptly rebalanced the Fund’s portfolio accordingly.

Shortly after the rebalancing error was identified, the Fund’s investment team implemented internal control and process enhancements designed to prevent the re-occurrence of the error.

The Adviser decided to transition management of the Fund from the existing team to the investment team in Invesco Capital Management LLC’s (“ICM”) ETFs and Indexed Strategies Group. This change was effective on July 13, 2020.

Upon assuming management of the Fund, ICM’s investment team immediately implemented its standard index fund management procedures and added the

Fund to its proprietary platform. ICM’s investment team has successfully rebalanced the Fund since assuming responsibility for its management.

Finally, the Adviser’s Investment Risk Management team has enhanced its process for daily monitoring of active/excess returns and tracking error in passive funds.

In addition to the trade error Adviser pay-in, Invesco remediated the Fund and certain shareholders who transacted in the Fund during the period consistent with the provisions of the Fund’s NAV Error Correction Policy.

The Registrants confirm that future shareholder reports will remove the reference indicating such bonds are issued by the state of Arkansas.

Effective with the August 31, 2021 reporting cycle, Invesco updated the disclosures for unfunded loan commitments. Unfunded loan commitments are shown as a holding in the Schedule of Investments and reflected as a liability on the Statement of Assets and Liabilities for the fair market value.  The notes to the financial statements disclose the commitment amount as well as the unrealized appreciation (depreciation) associated with each unfunded position.

The Registrants believe that the current disclosure meets applicable requirements.  Nonetheless, the disclosure will be enhanced in future shareholder reports to include the requested break-out of receivables and payables related to TBAs and mortgage dollar rolls on the Statement of Assets and Liabilities.

The Registrants confirm that all three of the Funds’ payment in-kind Income was less than 5% of total investment income for the fiscal year ended February 28, 2021.  It is the Funds’ policy to report the income separately as required by Regulation S-X 210.6-08.

The Registrant has determined to amend the Fund’s N-CSR to include a revised independent auditor report from PwC with the correct predecessor fund referenced.

The disclosure policy on US Treasury Bills is to disclose the discount rate at the time of purchase by the Fund and include a footnote to the Schedule of Investments stating that the security is traded on a discount basis and the interest rate shown represents the discount rate at the time of purchase by the Fund.  For Corporate Bonds and Municipal Bonds, the interest rate shown is the rate at the end of the reporting period and includes a footnote to the Schedule of Investments stating that it is a zero coupon bond issued at a discount.

Invesco Global Allocation Fund holds sidecar investments otherwise known as Catastrophe Linked Bonds/Notes. The catastrophe bonds do not accrue interest or amortize discount and/or premiums.  In the event of a catastrophic incident, proceeds may be received by the Fund and are recorded to income.  A zero coupon bond does not accrue interest but it does amortize original bond discount and premiums.

The Registrant confirms that the significant redemption from the Fund’s Class A shares was unrelated to the strategy change.  Due to the decrease in net assets of the Fund resulting from the redemption, the average net assets for the year which is used to calculate the expense ratios also decreased and as a result caused an increase in the Fund’s gross expense ratio. However, the Fund had expense limitation arrangements in place and therefore there was no impact to the Fund’s net expense ratio. The significant redemption and the liquidation of the Fund’s wholly owned subsidiary in 2020 resulted in increased trading activity and an increase to the Fund’s portfolio turnover.  The Registrant notes that the Fund’s annual report for the period ended October 31, 2020 includes a discussion of the Fund’s repositioning in the Management’s Discussion of Fund Performance.