Balanced Fund/VA
Shareholder Fees (fees paid directly from your investment): |
|
|
|
Non-Service Shares |
Service Shares |
Maximum Sales Charge (Load) imposed on purchases (as % of offering price) |
None |
None |
Maximum Deferred Sales Charge (Load) imposed on purchases (as % of the lower original offering price or redemption proceeds) |
None |
None |
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment) |
||
|
Non-Service Shares |
Service Shares |
Management Fees |
0.75% |
0.75% |
Distribution and/or Service (12b-1) Fees |
None |
0.25% |
Acquired Fund Fees and Expenses |
0.02% |
0.02% |
Other Expenses |
0.14% |
0.15% |
Total Annual Fund Operating Expenses |
0.91% |
1.17% |
Fee Waiver and Expense Reimbursement* |
(0.23%) |
(0.24%) |
Total Annual Fund Operating Expenses After Fee Waiver |
0.68% |
0.93% |
* The Manager has voluntarily agreed to waive a portion of the management fee and/or reimburse certain expenses so that total annual fund operating expenses will not exceed 0.67% of average annual net assets for Non-Service Shares and 0.92% of average annual net assets for Service Shares. The Manager has also voluntarily agreed to waive
fees and/or reimburse Fund expenses in an amount equal to the indirect management fees incurred through the Fund's investment in Oppenheimer Institutional Money Market Fund. Each undertaking may be amended or withdrawn after one year from the date of this prospectus.
Capital Appreciation Fund/VA
Shareholder Fees (fees paid directly from your investment): |
|
|
|
Non-Service Shares |
Service Shares |
Maximum Sales Charge (Load) imposed on purchases (as % of offering price) |
None |
None |
Maximum Deferred Sales Charge (Load) imposed on purchases (as % of the lower original offering price or redemption proceeds) |
None |
None |
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment) |
|
|
|
Non-Service Shares |
Service Shares |
Management Fees |
0.66% |
0.66% |
Distribution and/or Service (12b-1) Fees |
None |
0.25% |
Other Expenses |
0.12% |
0.13% |
Total Annual Fund Operating Expenses |
0.78% |
1.04% |
Fee Waiver and Expense Reimbursement* |
0.00% |
(0.01%) |
Total Annual Fund Operating Expenses after Fee Waiver and Expense Reimbursement |
0.78% |
1.03% |
* Since May 1, 2009, the Manager has voluntarily agreed to limit the Fund's total annual operating expenses so that those expenses, as percentages of daily net assets, would not exceed the annual rate of 0.80% for Non-Service shares and 1.05% for Service shares. This undertaking may be amended or withdrawn after one year from the date of this prospectus.
Core Bond Fund/VA
Shareholder Fees (fees paid directy from your investment): |
|
|
|
Non-Service Shares |
Service Shares |
Maximum Sales Charge (Load) imposed on purchases (as % of offering price) |
None |
None |
Maximum Deferred Sales Charge (Load) imposed on purchases (as % of the lower original offering price or redemption proceeds) |
None |
None |
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment) |
|
|
|
Non-Service Shares |
Service Shares |
Management Fees |
0.60% |
0.60% |
Distribution and/or Service (12b-1) Fees |
None |
0.25% |
Other Expenses |
0.15% |
0.16% |
Acquired Fund Fees and Expenses |
0.01% |
0.01% |
Total Annual Fund Operating Expenses |
0.76% |
1.02% |
Fee Waiver and Expense Reimbursement* |
(0.01)% |
(0.02)% |
Total Annual Fund Operating Expenses After Fee Waiver and Expense Reimbursement |
0.75% |
1.00% |
*Since May 1, 2009, the Manager has voluntarily agreed to limit the Fund's total annual operating expenses so that those expenses, as percentages of daily net assets, will not exceed the annual rate of 0.75% for Non-Service Shares and 1.00% for Service Shares. The Manager has also voluntarily agreed to waive fees and/or reimburse Fund expenses in an amount equal to the indirect management fees incurred through the Fund's investment in Oppenheimer Institutional Money Market Fund. Each undertaking may be amended or withdrawn after one year from the date of this prospectus.
Global Securities Fund/VA
Shareholder Fees (fees paid directly from your investment): |
|
|||
|
Non-Service Shares |
Service Shares |
Class 3 Shares |
Class 4 Shares |
Maximum Sales Charge (Load) imposed on purchases (as % of offering price) |
None |
None |
None |
None |
Maximum Deferred Sales Charge (Load) imposed on purchases (as % of the lower original offering price or redemption proceeds) |
None |
None |
None |
None |
Redemption Fee (as % of amount redeemed, if applicable) |
None |
None |
1.00% |
1.00% |
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment) |
||||
|
Non-Service Shares |
Service Shares |
Class 3 Shares |
Class 4 Shares |
Management Fees |
0.64% |
0.64% |
0.64% |
0.64% |
Distribution and/or Service (12b-1) Fees |
None |
0.25% |
None |
0.25% |
Other Expenses |
0.11% |
0.11% |
0.11% |
0.11% |
Total Annual Fund Operating Expenses |
0.75% |
1.00% |
0.75% |
1.00% |
Global Strategic Income Fund/VA
Shareholder Fees (fees paid directly from your investment): |
|
|
|
Non-Service Shares |
Service Shares |
Maximum Sales Charge (Load) imposed on purchases (as % of offering price) |
None |
None |
Maximum Deferred Sales Charge (Load) imposed on purchases (as % of the lower original offering price or redemption proceeds) |
None |
None |
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment) |
||
|
Non-Service Shares |
Service Shares |
Management Fees |
0.55% |
0.55% |
Distribution and/or Service (12b-1) Fees |
None |
0.25% |
Other Expenses |
0.10% |
0.10% |
Acquired Fund Fees and Expenses |
0.03% |
0.03% |
Total Annual Fund Operating Expenses |
0.68% |
0.93% |
Fee Waiver and Expense Reimbursement* |
(0.03%) |
(0.03%) |
Total Annual Fund Operating Expenses After Fee Waiver and Expense Reimbursement |
0.65% |
0.90% |
* The Manager has voluntarily agreed to waive fees and/or reimburse Fund expenses in an amount equal to the indirect management fees incurred through the Fund's investment in Oppenheimer Institutional Money Market Fund, Oppenheimer Master Loan Fund, LLC and Oppenheimer Master Event-Linked Bond Fund, LLC. This undertaking may be amended or withdrawn after one year from the date of this prospectus.
High Income Fund/VA
Shareholder Fees (fees paid directly from your investment): |
|
|||
|
Non-Service Shares |
Service Shares |
Class 3 Shares |
Class 4 Shares |
Maximum Sales Charge (Load) imposed on purchases (as % of offering price) |
None |
None |
None |
None |
Maximum Deferred Sales Charge (Load) imposed on purchases (as % of the lower original offering price or redemption proceeds) |
None |
None |
None |
None |
Redemption Fee (as % of amount redeemed, if applicable) |
None |
None |
1.00% |
1.00% |
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment) |
|
|
|
|
|
Non-Service Shares |
Service Shares |
Class 3 Shares |
Class 4 Shares |
Management Fees |
0.75% |
0.75% |
0.75% |
0.75% |
Distribution and/or Service (12b-1) Fees |
None |
0.25% |
None |
0.25% |
Acquired Fund Fees and Expenses |
0.02% |
0.02% |
0.02% |
0.02% |
Other Expenses |
0.19% |
0.21% |
0.22% |
0.19% |
Total Annual Fund Operating Expenses |
0.96% |
1.23% |
0.99% |
1.21% |
Fee Waiver and Expense Reimbursement* |
(0.11%) |
(0.15%) |
(0.18%) |
(0.13%) |
Total Annual Fund Operating Expenses After Fee Waiver and Expense Reimbursement |
0.85% |
1.08% |
0.81% |
1.08% |
* Since May 1, 2009, the Manager has voluntarily agreed to limit the Fund's total annual operating expenses so that those expenses, as percentages of daily net assets, will not exceed the annual rate of 0.75% for Non-Service and Class 3 shares and 1.00% for Service and Class 4 shares. The Manager has also voluntarily agreed to waive fees and/or reimburse Fund expenses in an amount equal to the indirect management fees incurred through the Fund's investment in Oppenheimer Institutional Money Market Fund. Each undertaking may be amended or withdrawn after one year from the date of this prospectus.
Main Street Small Cap Fund/VA
Shareholder Fees (fees paid directly from your investment): |
|
|
|
Non-Service Shares |
Service Shares |
Maximum Sales Charge (Load) imposed on purchases (as % of offering price) |
None |
None |
Maximum Deferred Sales Charge (Load) imposed on purchases (as % of the lower original offering price or redemption proceeds) |
None |
None |
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment) |
||
|
Non-Service Shares |
Service Shares |
Management Fees |
0.71% |
0.71% |
Distribution and/or Service (12b-1) Fees |
n/a |
0.25% |
Other Expenses |
0.20% |
0.19% |
Total Annual Fund Operating Expenses |
0.91% |
1.15% |
Fee Waiver and Expense Reimbursement* |
-0.09% |
-0.08% |
Total Annual Fund Operating Expenses After Fee Waiver and Expense Reimbursement |
0.82% |
1.07% |
*Since May 1, 2009, the Manager has voluntarily agreed to limit the Fund's total annual operating expenses so that those expenses, as percentages of daily net assets, will not exceed the annual rate of 0.80% for Non-Service Shares and 1.05% for Service Shares. This undertaking may be amended or withdrawn after one year from the date of this prospectus.
Money Fund/VA
Shareholder Fees (fees paid directly from your investment): |
|
|
|
Maximum Sales Charge (Load) imposed on purchases (as % of offering price) |
None |
Maximum Deferred Sales Charge (Load) imposed on purchases (as % of the lower original offering price or redemption proceeds) |
None |
Annual Fund Operating Expenses (expenses you pay each year as a percentage of the value of your investment) |
|
|
|
Management Fees |
0.45% |
Distribution and/or Service (12b-1) Fees |
None |
Other Expenses |
0.12% |
Total Annual Fund Operating Expenses |
0.57% |
Fee Waiver and Expense Reimbursement* |
(0.09%) |
Total Annual Fund Operating Expenses after Fee Waiver and Expense Reimbursement |
0.48% |
*Since May 1, 2009, the Manager has voluntarily agreed to limit the Fund's total annual operating expenses so that those expenses, as a percentage of daily net assets, will not exceed the annual rate of 0.50%. The Manager has also voluntarily undertaken to waive fees and/or reimburse expenses to the extent necessary to assist the Fund in attempting to maintain a positive yield.
Main Street Fund/VA
Shareholder Fees (fees paid directly from your investment): |
|
|
|
Non-Service Shares |
Service Shares |
Maximum Sales Charge (Load) imposed on purchases (as % of offering price) |
None |
None |
Maximum Deferred Sales Charge (Load) imposed on purchases (as % of the lower original offering price or redemption proceeds) |
None |
None |
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment) |
||
|
Non-Service Shares |
Service Shares |
Management Fees |
0.66% |
0.66% |
Distribution and/or Service (12b-1) Fees |
None |
0.25% |
Other Expenses |
0.12% |
0.12% |
Total Annual Fund Operating Expenses |
0.78% |
1.03% |
Small- & Mid- Cap Growth Fund/VA
Shareholder Fees (fees paid directly from your investment): |
|
|
|
Non-Service Shares |
Service Shares |
Maximum Sales Charge (Load) imposed on purchases (as % of offering price) |
None |
None |
Maximum Deferred Sales Charge (Load) imposed on purchases (as % of the lower original offering price or redemption proceeds) |
None |
None |
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment) |
|
|
|
Non-Service Shares |
Service Shares |
Management Fees |
0.73% |
0.73% |
Distribution and/or Service (12b-1) Fees |
None |
0.25% |
Other Expenses |
0.13% |
0.14% |
Total Annual Fund Operating Expenses |
0.86% |
1.12% |
Fee Waiver and Expense Reimbursement* |
(0.02%) |
(0.02%) |
Total Annual Fund Operating Expenses After Fee Waiver and Expense Reimbursement |
0.84% |
1.10% |
* Since May 1, 2009, the Manager has voluntarily agreed to limit the Fund's total annual operating expenses so that those expenses, as percentages of daily net assets, will not exceed the annual rate of 0.80% for Non-Service Shares and 1.05% for Service Shares. This undertaking may be amended or withdrawn after one year from the date of this
prospectus.
Value Fund/VA
Shareholder Fees (fees paid directly from your investment): |
|
|
|
Non-Service Shares |
Service Shares |
Maximum Sales Charge (Load) imposed on purchases (as % of offering price) |
None |
None |
Maximum Deferred Sales Charge (Load) imposed on purchases (as % of the lower original offering price or redemption proceeds) |
None |
None |
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment) |
||
|
Non-Service Shares |
Service Shares |
Management Fees |
0.75% |
0.75% |
Distribution and/or Service (12b-1) Fees |
None |
0.22% |
Acquired Fund Fees and Expenses |
0.01% |
0.01% |
Other Expenses |
1.55% |
1.20% |
Total Annual Fund Operating Expenses |
2.31% |
2.18% |
Fee Waiver and Expense Reimbursement* |
(0.76%) |
(0.73%) |
Total Annual Fund Operating Expenses After Fee Waiver |
1.55% |
1.45% |
* Since May 1, 2009, the Manager has voluntarily agreed to limit the Fund's total annual operating expenses so that those expenses, as percentages of daily net assets, will not exceed the annual rate of 0.80% for Non-Service Shares and 1.05% for Service Shares. The Manager has also voluntarily agreed to waive fees and/or reimburse Fund expenses in an amount equal to the indirect management fees incurred through the Fund's investment in Oppenheimer Institutional Money Market Fund. Each undertaking may be amended or withdrawn after one year from the date of this prospectus.
OppenheimerFunds, Inc.
Two World Financial Center
225 Liberty Street, 16th Floor
New York, New York 10281-1008
April 21, 2010
Via Electronic Transmission
Michael Kosoff, Esq.
Senior Counsel
U.S. Securities and Exchange Commission
Office of Insurance Products
100 F Street, NE
Washington, DC 20549
Re: Oppenheimer Variable Account Funds
Post-Effective Amendment No. 55 to the Registration Statement on Form N-1A
(SEC File No. 002-93177)
Dear Mr. Kosoff:
Pursuant to your request in your comments of April 9 on Post-Effective Amendment No. 55 to the registration statement of Oppenheimer Variable Account Funds (SEC File No. 002-93177), attached are completed fee tables (including any footnotes) for the following Oppenheimer Variable Account Funds:
Balanced Fund/VA
Capital Appreciation Fund/VA
Core Bond Fund/VA
Global Securities Fund/VA
Global Strategic Income Fund/VA
High Income Fund/VA
Main Street Fund/VA
Main Street Small Cap Fund/VA
Money Fund/VA
Small- & Mid-Cap Growth Fund/VA
Value Fund/VA
Please direct any questions you may have regarding the amendment or this letter to:
Nancy S. Vann
OppenheimerFunds, Inc.
Two World Financial Center
225 Liberty Street, 16th Floor
New York, New York 10281-1008
Tel: (212) 323-5089
Fax: (212) 321-4071
nvann@oppenheimerfunds.com
Sincerely,
/s/ Taylor V. Edwards
Taylor V. Edwards
Vice President and Associate Counsel
cc: Eric Purple, Esq.
Kate Ives, Esq.
Gloria LaFond