SIGNIFICANT
ACCOUNTING
POLICIES
Valuation
of
Investments
—
The
Portfolios
record
their
investments
at
fair
value
using
market quotations
when
they
are
readily
available
pursuant
to Rule
2a-5.
The
Portfolios'
investments
are
recorded
at
fair value
determined
in
good
faith
when
market
quotations
are
not
readily
available.
Securities
traded
on
U.S.
or
foreign
securities
exchanges
or
included
in
a
national
market
system
are
valued
at
the last
sale price
on
the
principal exchange as
of the
close
of
regular
trading
on
such
exchange
or
the
official
closing
price
of
the
national
market
system.
Over-the-counter
securities
and
listed
securities
for
which
no
price
is
readily
available
are
valued
at
the
current
bid
price
considered
best
to
represent
the
value
at
that
time.
Security
prices
are
based
on
quotes
that
are
obtained
from
an
independent
pricing
service
approved
by
the
Fund's
Board
of
Directors
(the
“Board”).
The
pricing
service,
in
determining
values
of
fixed-income
securities,
takes
into
consideration
such
factors
as
current
quotations
by
broker/dealers,
coupon,
maturity,
quality,
type
of
issue,
trading
characteristics,
and
other
yield
and
risk
factors
it
deems
relevant
in
determining
valuations.
Securities
which
cannot
be
valued
by
the
approved
pricing
service
are
valued
using
valuations obtained from dealers
that
make
markets
in
the
securities.
Exchange-listed
options and
futures
contracts
are
valued
at
the
primary
exchange
settle
price.
Exchange
cleared
swap
agreements
are
valued at the
clearinghouse
end
of
day
price. Swap
agreements
not
cleared
on
exchanges
will
be
valued
using
the
mid-price
from
the
primary
approved
pricing
service. Forward
foreign
currency
exchange
contracts
are
marked-to-market
based
upon
foreign
currency
exchange rates
provided
by the
pricing
service.
Investments
in
open-ended
mutual
funds
are
valued
at
their
net
asset
value
at
the
close
of
each
business
day.
Thrivent
Money
Market Portfolio
seeks
to
maintain
a
stable
net
asset
value
of
$1.00
per
share,
pursuant
to
procedures
established
by
the
Board,
and
generally
utilizes
the
amortized
cost
method.
Valuing
securities
held
by
Thrivent
Money
Market Portfolio
on
the
basis
of
amortized
cost
(which
approximates
market
value)
involves
a
constant
amortization
of
premium
or
accretion
of
discount
to
maturity.
The
Thrivent
Money
Market Portfolio
will
not
value
a
security
at
amortized
cost,
but
will
instead
make
a
fair
value
determination
of
each
security,
if
it
determines
that
amortized
cost
is
not
approximately
the
same
as
the
fair
value
of
the
security.
The
Board
has
chosen the
Portfolios'
Investment
Adviser
as
the
valuation
designee,
responsible
for
daily
valuation
of
the
Portfolios'
securities.
The
Adviser
has
formed
a
Valuation
Committee
(the
“Committee”)
that
is
responsible
for
overseeing
the
Portfolios’
valuation
policies
in
accordance
with
Valuation
Policies
and
Procedures.
The
Committee
meets
on
a
monthly
and
on
an
as-
needed
basis
to
review
price
challenges,
price
overrides,
stale
prices,
shadow
prices,
manual
prices,
money
market
pricing,
international
fair
valuation,
and
other
securities
requiring
fair
valuation.
The
Committee
monitors
for
significant
events
occurring
prior
to
the
close
of
trading
on
the
New
York
Stock
Exchange
that
could
have
a
material
impact
on
the
value
of
any
securities
that
are
held
by
the
Portfolios.
Examples
of
such
events
include
trading
halts,
national
news/events,
and
issuer-specific
developments.
If
the
Committee
decides
that
such
events
warrant
using
fair
value
estimates,
the
Committee
will
take
such
events
into
consideration
in
determining
the
fair
value
of
such
securities.
If
market
quotations
or
prices
are
not
readily
available
or
determined
to
be
unreliable,
the
securities
will
be
valued
at
fair
value
as
determined
in
good
faith
pursuant
to
procedures
adopted
by
the
Board.
In
accordance
with U.S.
Generally
Accepted
Accounting
Principles
(“GAAP”),
the
various
inputs
used
to
determine
the
fair
value
of
the
Portfolios’
investments
are
summarized
in
three
broad
levels.
Level
1
includes
quoted
prices
in
active
markets
for
identical
securities,
typically included
in
this
level
are
U.S.
equity
securities,
futures, options
and
registered
investment
company
funds.
Level
2
includes
other
significant
observable
inputs
such
as
quoted
prices
for
similar
securities,
interest
rates,
prepayment
speeds
and
credit
risk,
typically
included
in
this
level
are
fixed
income
securities,
international securities,
swaps
and
forward
contracts.
Level
3
includes
significant
unobservable
inputs
such
as
the
Adviser’s
own
assumptions
and
broker
evaluations
in
determining
the
fair
value
of
investments.
The
valuation
levels
are
not
necessarily
an
indication
of
the
risk
associated
with
investing
in
these
securities
or
other
investments.
Investments
measured
using
net
asset
value
per
share
as
a
practical
expedient
for
fair
value
and
that
are
not
publicly
available-for-sale are
not
categorized
within
the
fair
value
hierarchy.
Valuation
of
International
Securities
—
The
Portfolios
value
certain
foreign
securities
traded
on
foreign
exchanges
that
close
prior
to
the
close
of
the
New
York
Stock
Exchange
using
a
fair
value
pricing
service.
The
fair
value
pricing
service
uses
a
multi-factor
model
that
may
take
into
account
the
local
close,
relevant
general
and
sector
indices,
currency
fluctuation,
prices
of
other
securities
(including
ADRs,
New
York
registered
shares,
and
ETFs),
and
futures,
as
applicable,
to
determine
price
adjustments
for
each
security
in
order
to
reflect
the
effects
of
post-closing
events.
The
Board
has
authorized
the
Adviser
to
make
fair
valuation
determinations
pursuant
to
policies
approved
by
the
Board.
Foreign
Currency
Translation
—
The
accounting
records
of
each
Portfolio
are
maintained
in
U.S.
dollars.
Securities
and
other
assets
and
liabilities
that
are
denominated
in
foreign
currencies
are
translated
into
U.S.
dollars
at
the
daily
closing
rates
of
exchange.
Foreign
currency
amounts
related
to
the
purchase
or
sale
of
securities
and
income
and
expenses
are
translated
at
the
exchange
rate
on
the
transaction
date.
Net
realized
and
unrealized
currency
gains
and
losses
are
recorded
from
closed currency
contracts,
disposition
of foreign
currencies,
exchange
gains
or
losses
between
the
trade
date
and
settlement
date
on
securities
transactions,
and
other
translation
gains
or
losses
on
dividends,
interest
income
and
foreign
withholding
taxes.
The
Portfolios
do
not
separately
report
the
effect
of
changes
in
foreign
exchange