Lincoln Variable Insurance Products Trust CORRESPCorrespondence with SEC

The Registrant must file its responses on EDGAR no later than 5 business days before the effective date of the Registration Statement.

The Registrant is responsible for the accuracy and adequacy of its disclosure notwithstanding review by the Staff.

Please note that where a comment is made in one section such comment should be addressed in all other sections where it applies in the Registration Statement.

Add headings to the Item 9 discussion of the Funds’ principal risks.

Given the mention of environmental, science and governance (“ESG”) integration within the strategy for the Fund, consider more clearly explaining the definition of ESG and whether all three factors are given equal weighting in the Item 9 discussion of the investment strategy. If the Fund is ESG-focused, please include the Fund’s ESG proxy voting policy or a discussion of why one is not included. If the fund is an ESG-focused fund, include disclosure in the Item 9 discussion of the investment strategy relating to the scoring models used by the Fund and the third-party sources of data for scoring along with an ESG risk that discloses such providers.

Consider clarifying what the Fund considers to be “equity” in the Item 4 discussion of the investment strategy.

Please revise the use of “may” in the discussion of the Fund’s strategy in order to clarify what the portfolio managers “intend to” do.

In reference to the statement, “Final scores for each security are evaluated on a sector-specific basis, and the fund seeks to hold securities with the strongest scores in their respective sectors. Using this process, the portfolio managers attempt to build a portfolio of stocks that has sustainable competitive advantages, provides better returns without taking on significant additional risk, and maintains a stronger ESG profile than the S&P 500 Index,” please clarify how this will be measured and whether the index has an ESG profile.

Consider including an explanation of what the Fund means by “Large Cap.”

Disclose whether the Fund’s ESG criteria will be applied to each security selected or whether other criteria will also be considered. For example, if ESG information about a security is incomplete, will such a security still be selected?

Disclose in the discussion of the investment strategy in Items 4 and 9 (1) what is the expected allocation split between equity and fixed income; (2) whether “high-and medium-grade money market debt securities” means “investment grade” or define it otherwise; whether ESG will also be considered for the fixed income portfolio; (3) whether there will also be non-U.S. fixed income securities; (4) and whether collateralized loan obligations will include covenant light loans. If covenant light loans are included in this definition, include a corresponding principal risk.

Clarify what derivatives the fund intends to invest in, as opposed to what it may invest in, and what those derivatives will be used for.

Given “Foreign Securities Risk,” please consider mention of such foreign securities, and disclosure that those securities may experience stale prices if local markets are closed, in the discussion of the Fund’s investment strategy. Further, if the Fund invests in emerging markets, include a definition of what the Fund considers to be an emerging market.

Consider tailoring “Derivatives Risk” to the specific derivatives that pose risks as a principal investment in the Fund.

State supplementally the performance benchmark for the Fund.

In reference to the statement, “The team arrives at an ESG score by evaluating multiple metrics of each ESG characteristic— environmental, social, and governance,” in the Item 9 discussion of the investment strategy, please begin a new paragraph here.

In reference to the statement in Comment 15 above, if the Fund is an ESG-focused fund identify the sources of third-party data used in scoring. If the Fund is an ESG integration fund, please state that ESG is one of several factors considered and that securities with a low ESG score may still be selected.

In reference to the statement, “Most of the fixed-income assets will be invested in securities that are rated within the four highest categories by a nationally recognized statistical rating organization,” please clarify what portion is meant by “most” and whether below investment grade bonds are included as a principal investment.

Remove the reference to “VP Balanced” in the Item 9 discussion of the Fund’s principal risks.

Consider revising the Fund’s principal risks to refer to risks that the Fund “will” or “intends to” be subject to as opposed to those it “may” be subject to.

In the Item 4 discussion of the Fund’s investment strategy, clarify if “stock” refers only to common stock and whether this refers to U.S. stocks.

In the Item 4 discussion of the Fund’s investment strategy, define “medium-sized companies.”

In reference to the statement, “Management of the fund is based on the belief that durable franchises in a growing industry can sustain above average earnings growth” in the Item 4 discussion of the Fund’s investment strategy clarify whether the Fund intends to invest in “durable franchises” and, if so, define.

In the Item 4 discussion of the Fund’s investment strategy, clarify whether the Fund intends to concentrate in a particular sector.

In reference to the statement, “Analytical indicators helping to identify signs of business improvement could include accelerating earnings or revenue growth rates, increasing cash flows, or other indications of the relative strength of a company’s business,” clarify what indicators “will” include.

Consider moving the discussion of ESG factors to the Item 9 discussion of the Fund’s strategy.

In reference to the statement, “The fund will usually purchase common stocks of companies that are medium-sized at the time of purchase, but it will purchase securities of smaller- and larger-sized companies as well,” please clarify what is meant by “usually purchase” and whether there are limits on the capitalization of securities purchased.

In the discussion of the Fund’s investment strategy, clarify whether there is a limit on foreign securities and whether the Fund intends to invest in emerging markets. If the Fund intends to invest in emerging markets, define.

In reference to the statement, “The fund may write covered calls on a portion of the fund’s holdings in common stock when the portfolio managers believe call premiums are attractive relative to the price of the underlying security,” unless the fund “intends to” or “will” use covered calls please move to the Statement of Additional Information (“SAI”).

Consider moving “ESG Integration Risk” to the Item 9 discussion of principal risks.

In the Item 9 discussion of the investment strategy, disclose whether the Fund will continue to hold medium-sized companies if they become small- or large-sized companies over time.

In the discussion of the Fund’s investment strategy, clarify whether the Fund will only invest in the constituents of the S&P 500^® Index.

In the discussion of the Fund’s investment strategy, clarify whether “stocks” refers to common stock.

Clarify why “Low Dividend Yield Risk” is a principal risk to the fund in the discussion of the Funds investment strategy.

Please explain why “Price Volatility Risk” is a principal risk to the fund.

In the Item 9 discussion of the Fund’s investment strategy, clarify which of the securities listed in the definition of “Equity Securities” the Fund intends to invest in as a principal investment and add corresponding risks and discussion in Item 4.

In reference to the statement, “Although current income is an objective for the fund, if the stocks that make up the S&P 500^® Index do not have a high dividend yield, then the fund’s dividend yield will not be high” in the Item 9 discussion of the Fund’s principal risks, please explain why this is not referencing the Fund’s performance benchmark.

In reference to the statement, “To help protect against U.S. inflation, under normal conditions the fund will invest over 50% of its assets in inflation-indexed debt securities” please explain why the Fund may not invest in more than 55% in U.S. Treasuries as noted in Inflation Risk.

In the discussion of the Fund’s investment strategy, clarify whether there is a limit on foreign inflation-indexed securities and whether the Fund intends to invest in emerging markets. If the Fund intends to invest in emerging markets, define.

Consider including an 80% policy related to Inflation Protection in the name of the Fund.

Please revise the use of “may” in the discussion of the Fund’s strategy relating to derivatives in order to clarify what the portfolio managers “intend to” do.

Clarify whether collateralized loan obligations will include covenant light loans and, if so, disclose whether the Fund intends to invest in these as a principal investment and include a corresponding principal risk.

Consider moving the following statement to the Item 9 discussion of the Fund’s strategy:

Consider tailoring “Derivatives Risk” to the specific derivatives that pose risks as a principal investment in the Fund.

Clarify whether “Bank Loan Risk” is relevant to principal investments used by the Fund and, if not, delete.

Clarify whether the Fund may invest in issuers of any market capitalization.

Clarify what percentage of assets will be in “non-U.S.” issuers and how the Fund defines this.

Clarify whether the Fund invests in emerging markets and, if so, include a definition of what the Fund considers to be an emerging market.

Given the mention of environmental, science and governance ESG integration within the strategy for the Fund, consider more clearly explaining the definition of ESG and whether all three factors are given equal weighting in the Item 9 discussion of the investment strategy. If the Fund is ESG-focused, please include the Fund’s ESG proxy voting policy or a discussion of why one is not included. If the Fund is an ESG integration fund, note that ESG is one of a number of factors that are considered. If the fund is an ESG-focused fund, include disclosure in the Item 9 discussion of the investment strategy relating to the scoring models used by the Fund and the third-party sources of data for scoring along with an ESG risk that discloses such providers.

Consider clarifying what the Fund considers to be “equity” in the Item 4 discussion of the investment strategy and include corresponding risk factors.

In reference to the statement, “Equity securities include common stock, preferred stock, and equity-equivalent securities, such as securities convertible into common stock, stock futures contracts or stock index futures contracts” please define stock futures contracts or stock index futures contracts.

In reference to the statement, “However, the fund can purchase other types of securities as well, such as forward currency exchange contracts, notes, bonds and other debt securities of companies, and obligations of domestic or foreign governments and their agencies” please clarify whether these are

principal investments and, if so, identify them in the Item 4 discussion of the investment strategy as principal investments and describe associated risks. If not, note this in the Item 9 discussion of the Fund’s investment strategy.

Please clarify what price is referred to and what the based of comparison is for the following statement, “This volatility can be greater than that of the average stock fund,” in the Item 9 description of the Fund’s principal risks.

In reference to the statement, “Investing a significant portion of assets in one country or region makes the fund more dependent upon the political and economic circumstances of that country or region than funds that invest more broadly,” in the Item 9 description of the Fund’s principal risks, please note what country this references.

Please include “(including borrowings for investment purposes)” in the Fund’s 80% policy language.

Given the mention of environmental, science and governance ESG integration within the strategy for the Fund, consider more clearly explaining the definition of ESG and whether all three factors are given equal weighting in the Item 9 discussion of the investment strategy. If the Fund is ESG-focused, please include the Fund’s ESG proxy voting policy or a discussion of why one is not included. If the Fund is an ESG integration fund, note that ESG is one of a number of factors that are considered. If the fund is an ESG-focused fund, include disclosure in the Item 9 discussion of the investment strategy relating to the scoring models used by the Fund and the third-party sources of data for scoring along with an ESG risk that discloses such providers.

Consider adding a risk relating to investment in large companies.

Consider clarifying what the Fund considers to be “equity” in the Item 4 discussion of the investment strategy and include corresponding risk factors.

Please include “(including borrowings for investment purposes)” in the Fund’s 80% policy language.

Given the mention of environmental, science and governance ESG integration within the strategy for the Fund, consider more clearly explaining the definition of ESG and whether all three factors are given equal weighting in the Item 9 discussion of the investment strategy. If the Fund is ESG-focused, please include the Fund’s ESG proxy voting policy or a discussion of why one is not included. If the Fund is an ESG integration fund, note that ESG is one of a number of factors that are considered. If the fund is an ESG-focused fund, include disclosure in the Item 9 discussion of the investment strategy relating to the scoring models used by the Fund and the third-party sources of data for scoring along with an ESG risk that discloses such providers.

Consider clarifying what the Fund considers to be “equity” in the Item 4 discussion of the investment strategy and include corresponding risk factors.

Consider removing Foreign Securities Risk from Item 4 and Item 9 risk sections if foreign securities are not a principal investment of the Fund.

Consider removing IPO Risk from Item 4 and Item 9 risk sections if initial public offerings are not a principal investment of the Fund.

In the discussion of the Fund’s strategy in Items 4 and 9, please clarify the Russell index used within the Fund.

Consider defining “larger-sized companies” in the discussion of the Fund’s investment strategy.

Consider clarifying whether “stocks” include only common stocks or other types of equity investments.

As it relates to the statement, “Among other variables, the portfolio managers will consider the fund’s growth and momentum profile relative to the benchmark,” clarify what the benchmark is.

In the discussion of the Fund’s investment strategy, clarify whether there is a limit on foreign securities and whether the Fund intends to invest in emerging markets. If the Fund intends to invest in emerging markets, define.

Clarify whether covered calls are the only form of derivative the Fund intends to use as a principal investments.

State that the Fund will be non-diversified in the discussion of its investment strategy.

Consider clarifying the term “stocks” as used in the Item 4 discussion of the Fund’s investment strategy includes only common stocks or whether other types of “Equity Securities” as contemplated in the Item 9 discussion of the Fund’s investment strategy are included in this definition.

In the discussion of the Fund’s investment strategy, clarify whether there is a limit on foreign securities and whether the Fund intends to invest in emerging markets. If the Fund intends to invest in emerging markets, define.

Given the mention of environmental, science and governance ESG integration within the strategy for the Fund, consider more clearly explaining the definition of ESG and whether all three factors are given equal weighting in the Item 9 discussion of the investment strategy. If the Fund is ESG-focused, please include the Fund’s ESG proxy voting policy or a discussion of why one is not included. If the Fund is an ESG integration fund, note that ESG is one of a number of factors that are considered. If the fund is an ESG-focused fund, include disclosure in the Item 9 discussion of the investment strategy relating to the scoring models used by the Fund and the third-party sources of data for scoring along with an ESG risk that discloses such providers.

Explain supplementally why fundamental restriction number one in the SAI does not conflict with the 55% limitation on the LVIP American Century Inflation Protection Fund’s net assets being invested in securities issued by the same entity, such as the U.S. Treasury.

Clarify in the discussion of the LVIP American Century Ultra^® Fund’s investment strategy that it is not diversified.

Please explain supplementally the purpose of this statement, “The Securities and Exchange Commission’s (“SEC”) staff has taken the position that, for purposes of the concentration disclosure requirement, a fund investing more than 25% of its assets in an industry may be concentrating in that industry. See Registration Form Used by Open-End Management Investment Companies, Investment

Company Act Release No. 23064 (Mar. 13, 1998), at note 163. Notwithstanding fundamental investment restriction 1 above, a Fund may concentrate in a particular industry to the extent that such concentration results from the Fund’s tracking or replication of an index.”