40-17F2 1 d641846d4017f2.htm GOLDMAN SACHS VARIABLE INSURANCE TRUST Goldman Sachs Variable Insurance Trust

 

 

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D. C. 20549

 

 

Form N-17f-2

 

 

Certificate of Accounting of Securities and Similar

Investments in the Custody of

Management Investment Companies

Pursuant to Rule 17f-2 [17 CFR 270.17f-2]

 

1. Investment Company Act File Number:   Date examination completed:
   
811-08361   November 16, 2023
2. State identification Number:
        AL   AK   AZ   AR   CA   CO
    CT   DE   DC   FL   GA   HI
    ID   IL   IN   IA   KS   KY
    LA   ME   MD   MA   MI   MN
    MS   MO   MT   NE   NV   NH
    NJ   NM   NY   NC   ND   OH
    OK   OR   PA   RI   SC   SD
    TN   TX   UT   VT   VA   WA
    WV   WI   WY   PUERTO RICO        
   

Other (specify):

 

                   

3. Exact name of investment company as specified in registration statement:

 

Goldman Sachs Variable Insurance Trust

4. Address of principal executive office (number, street, city, state, zip code):

 

71 South Wacker Drive, Chicago, IL 60606

 

 

 


Report of Independent Accountants

To the Board of Trustees of Goldman Sachs Variable Insurance Trust

We have examined management’s assertion, included in the accompanying Management Statement Regarding Compliance with Certain Provisions of the Investment Company Act of 1940, that each of the series of Goldman Sachs Variable Insurance Trust (as set forth in the attached Schedule of Funds) (hereafter individually referred to as the “Fund”) complied with the requirements of subsections (b) and (c) of Rule 17f-2 under the Investment Company Act of 1940 (“the Act”), as interpreted in management’s assertion as of March 31, 2023 with respect to shares of beneficial interest of the underlying funds owned by each Fund and held by Goldman Sachs & Co. LLC in book entry form. Management is responsible for its assertion and each Fund’s compliance with those requirements. Our responsibility is to express an opinion on management’s assertion about each Fund’s compliance with the specified requirements based on our examination.

Our examination was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and in accordance with attestation standards established by the American Institute of Certified Public Accountants. Those standards require that we plan and perform the examination to obtain reasonable assurance about whether management’s assertion about compliance with the specified requirements is fairly stated, in all material respects, and, accordingly, included examining, on a test basis, evidence about the Fund’s compliance with those requirements and performing such other procedures as we considered necessary in the circumstances. Included among our procedures were the following tests performed as of March 31, 2023 and with respect to agreement of purchases and sales of shares of beneficial interest of the underlying funds, for the period from July 31, 2022 (the date of our last examination), through March 31, 2023:

 

 

Confirmation of securities (the number of shares of beneficial interest of the underlying funds) owned by each Fund and held by Goldman Sachs & Co. LLC, a transfer agent that uses the book entry method of accounting for shares;

 

 

Reconciliation of all such securities (shares of beneficial interest of the underlying funds) to the books and records of each Fund and Goldman Sachs & Co. LLC; and

 

 

Agreement of a sample of purchases of shares of beneficial interest of the underlying funds and a sample of sales of shares of beneficial interest of the underlying funds by each Fund since our last report from the books and records of each Fund to confirmations received from Goldman Sachs & Co. LLC.

We believe that our examination provides, and that the evidence we obtained is sufficient and appropriate to provide, a reasonable basis for our opinion. Our examination does not provide a legal determination on each Fund’s compliance with specified requirements.

We are required to be independent and to meet our other ethical responsibilities in accordance with relevant ethical requirements related to the engagement.

In our opinion, management’s assertion that each of the series of Goldman Sachs Variable Insurance Trust (as set forth in the attached Schedule of Funds) complied with the requirements of subsections (b) and (c) of Rule 17f-2 of the Investment Company Act of 1940, as interpreted in management’s assertion as of March 31, 2023 with respect to shares of beneficial interest of the underlying funds owned by each Fund and held by Goldman Sachs & Co. LLC in book entry form, is fairly stated, in all material respects.

This report is intended solely for the information and use of management and the Board of Trustees of each Fund and the Securities and Exchange Commission and is not intended to be and should not be used by anyone other than these specified parties.

 

/s/ PricewaterhouseCoopers LLP
Boston, Massachusetts
November 16, 2023


Schedule of Funds

 

Fund
Goldman Sachs Buffered S&P 500 Fund - Jan/Jul
Goldman Sachs Buffered S&P 500 Fund - Mar/Sep
Goldman Sachs Core Fixed Income Fund
Goldman Sachs Trend Driven Allocation Fund
Goldman Sachs International Equity Insights Fund
Goldman Sachs Large Cap Value Fund
Goldman Sachs Mid Cap Growth Fund
Goldman Sachs Mid Cap Value Fund
Goldman Sachs Multi-Strategy Alternatives Portfolio
Goldman Sachs Small Cap Equity Insights Fund
Goldman Sachs Strategic Growth Fund
Goldman Sachs U.S. Equity Insights Fund


 

 

Goldman, Sachs & Co. LLC | 30 Hudson Street | Jersey City, NJ 07302                   
   Goldman   
   Sachs   

 

 

Management Statement Regarding Compliance with Certain Provisions of the Investment Company Act of 1940

We, as members of management of the funds listed in Appendix A, each a series of Goldman Sachs Variable Insurance Trust (each, a “Fund” and, together, the “Funds”), are responsible for complying with the requirements of subsections (b) and (c) of Rule 17f-2, Custody of Investments by Registered Management Investment Company, of the Investment Company Act of 1940 as interpreted, amended or modified based on SEC orders or SEC staff issued no-action guidance relevant to interests in underlying funds held by an affiliated transfer agent in book entry form (“Rule 17f-2”). We are also responsible for establishing and maintaining effective internal controls over compliance with those requirements. We have performed an evaluation of each Fund’s compliance with the requirements of Rule 17f-2 as of March 31, 2023 and from July 31, 2022 or, if a later date, the commencement of operations of a Fund through March 31, 2023.

Based on this evaluation, we assert that each Fund was in compliance with the requirements of Rule 17f-2 of the Investment Company Act of 1940 as of March 31, 2023, with respect to shares of beneficial interest of the underlying funds owned by each Fund and held by Goldman Sachs & Co. LLC in book entry form.

 

By:   /s/ Joseph F. DiMaria
  Joseph F. DiMaria
  Treasurer, Principal Financial Officer and Principal Accounting Officer of the Funds
 

Title

 

November 16, 2023

  Date

 

By:   /s/ Peter W. Fortner
  Peter W. Fortner
  Assistant Treasurer of the Funds
 

Title

 

November 16, 2023

  Date


Appendix A

 

Fund  
Goldman Sachs Buffered S&P 500 Fund - Jan/Jul  
Goldman Sachs Buffered S&P 500 Fund - Mar/Sep  
Goldman Sachs Core Fixed Income Fund  
Goldman Sachs Trend Driven Allocation Fund  
Goldman Sachs International Equity Insights Fund  
Goldman Sachs Large Cap Value Fund  
Goldman Sachs Mid Cap Growth Fund  
Goldman Sachs Mid Cap Value Fund  
Goldman Sachs Multi-Strategy Alternatives Portfolio  
Goldman Sachs Small Cap Equity Insights Fund  
Goldman Sachs Strategic Growth Fund  
Goldman Sachs U.S. Equity Insights Fund  


Report of Independent Accountants

To the Board of Trustees of Goldman Sachs Variable Insurance Trust

We have examined management’s assertion, included in the accompanying Management Statement Regarding Compliance with Certain Provisions of the Investment Company Act of 1940, that each of the series of Goldman Sachs Variable Insurance Trust (as set forth in the attached Schedule of Funds) (hereafter individually referred to as the “Fund”) complied with the requirements of subsections (b) and (c) of Rule 17f-2 under the Investment Company Act of 1940 (“the Act”), as interpreted in management’s assertion as of April 30, 2023 with respect to shares of beneficial interest of the underlying funds owned by each Fund and held by Goldman Sachs & Co. LLC in book entry form. Management is responsible for its assertion and each Fund’s compliance with those requirements. Our responsibility is to express an opinion on management’s assertion about each Fund’s compliance with the specified requirements based on our examination.

Our examination was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and in accordance with attestation standards established by the American Institute of Certified Public Accountants. Those standards require that we plan and perform the examination to obtain reasonable assurance about whether management’s assertion about compliance with the specified requirements is fairly stated, in all material respects, and, accordingly, included examining, on a test basis, evidence about the Fund’s compliance with those requirements and performing such other procedures as we considered necessary in the circumstances. Included among our procedures were the following tests performed as of April 30, 2023 and with respect to agreement of purchases and sales of shares of beneficial interest of the underlying funds, for the period from March 31, 2023 (the date of our last examination), through April 30, 2023:

 

 

Confirmation of securities (the number of shares of beneficial interest of the underlying funds) owned by each Fund and held by Goldman Sachs & Co. LLC, a transfer agent that uses the book entry method of accounting for shares;

 

 

Reconciliation of all such securities (shares of beneficial interest of the underlying funds) to the books and records of each Fund and Goldman Sachs & Co. LLC; and

 

 

Agreement of a sample of purchases of shares of beneficial interest of the underlying funds and a sample of sales of shares of beneficial interest of the underlying funds by each Fund since our last report from the books and records of each Fund to confirmations received from Goldman Sachs & Co. LLC.

We believe that our examination provides, and that the evidence we obtained is sufficient and appropriate to provide, a reasonable basis for our opinion. Our examination does not provide a legal determination on each Fund’s compliance with specified requirements.

We are required to be independent and to meet our other ethical responsibilities in accordance with relevant ethical requirements related to the engagement.

In our opinion, management’s assertion that each of the series of Goldman Sachs Variable Insurance Trust (as set forth in the attached Schedule of Funds) complied with the requirements of subsections (b) and (c) of Rule 17f-2 of the Investment Company Act of 1940, as interpreted in management’s assertion as of April 30, 2023 with respect to shares of beneficial interest of the underlying funds owned by each Fund and held by Goldman Sachs & Co. LLC in book entry form, is fairly stated, in all material respects.

This report is intended solely for the information and use of management and the Board of Trustees of each Fund and the Securities and Exchange Commission and is not intended to be and should not be used by anyone other than these specified parties.

 

/s/ PricewaterhouseCoopers LLP
Boston, Massachusetts
November 16, 2023


Schedule of Funds

 

Fund
Goldman Sachs Buffered S&P 500 Fund - Jan/Jul
Goldman Sachs Buffered S&P 500 Fund - Mar/Sep
Goldman Sachs Core Fixed Income Fund
Goldman Sachs Trend Driven Allocation Fund
Goldman Sachs International Equity Insights Fund
Goldman Sachs Large Cap Value Fund
Goldman Sachs Mid Cap Growth Fund
Goldman Sachs Mid Cap Value Fund
Goldman Sachs Multi-Strategy Alternatives Portfolio
Goldman Sachs Small Cap Equity Insights Fund
Goldman Sachs Strategic Growth Fund
Goldman Sachs U.S. Equity Insights Fund


 

 

Goldman, Sachs & Co. LLC | 30 Hudson Street | Jersey City, NJ 07302                   
   Goldman   
   Sachs   

 

 

Management Statement Regarding Compliance with Certain Provisions of the Investment Company Act of 1940

We, as members of management of the funds listed in Appendix A, each a series of Goldman Sachs Variable Insurance Trust (each, a “Fund” and, together, the “Funds”), are responsible for complying with the requirements of subsections (b) and (c) of Rule 17f-2, Custody of Investments by Registered Management Investment Company, of the Investment Company Act of 1940 as interpreted, amended or modified based on SEC orders or SEC staff issued no-action guidance relevant to interests in underlying funds held by an affiliated transfer agent in book entry form (“Rule 17f-2”). We are also responsible for establishing and maintaining effective internal controls over compliance with those requirements. We have performed an evaluation of each Fund’s compliance with the requirements of Rule 17f-2 as of April 30, 2023 and from March 31, 2023 through April 30, 2023.

Based on this evaluation, we assert that each Fund was in compliance with the requirements of Rule 17f-2 of the Investment Company Act of 1940 as of April 30, 2023, with respect to shares of beneficial interest of the underlying funds owned by each Fund and held by Goldman Sachs & Co. LLC in book entry form.

 

By:   /s/ Joseph F. DiMaria
  Joseph F. DiMaria
  Treasurer, Principal Financial Officer and Principal Accounting Officer of the Funds
 

Title

 

November 16, 2023

  Date

 

By:   /s/ Peter W. Fortner
  Peter W. Fortner
  Assistant Treasurer of the Funds
 

Title

 

November 16, 2023

  Date


Appendix A

 

Fund  
Goldman Sachs Buffered S&P 500 Fund - Jan/Jul  
Goldman Sachs Buffered S&P 500 Fund - Mar/Sep  
Goldman Sachs Core Fixed Income Fund  
Goldman Sachs Trend Driven Allocation Fund  
Goldman Sachs International Equity Insights Fund  
Goldman Sachs Large Cap Value Fund  
Goldman Sachs Mid Cap Growth Fund  
Goldman Sachs Mid Cap Value Fund  
Goldman Sachs Multi-Strategy Alternatives Portfolio  
Goldman Sachs Small Cap Equity Insights Fund  
Goldman Sachs Strategic Growth Fund  
Goldman Sachs U.S. Equity Insights Fund  


Report of Independent Accountants

To the Board of Trustees of Goldman Sachs Variable Insurance Trust

We have examined management’s assertion, included in the accompanying Management Statement Regarding Compliance with Certain Provisions of the Investment Company Act of 1940, that each of the series of Goldman Sachs Variable Insurance Trust (as set forth in the attached Schedule of Funds) (hereafter individually referred to as the “Fund”) complied with the requirements of subsections (b) and (c) of Rule 17f-2 under the Investment Company Act of 1940 (“the Act”), as interpreted in management’s assertion as of May 31, 2023 with respect to shares of beneficial interest of the underlying funds owned by each Fund and held by Goldman Sachs & Co. LLC in book entry form. Management is responsible for its assertion and each Fund’s compliance with those requirements. Our responsibility is to express an opinion on management’s assertion about each Fund’s compliance with the specified requirements based on our examination.

Our examination was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and in accordance with attestation standards established by the American Institute of Certified Public Accountants. Those standards require that we plan and perform the examination to obtain reasonable assurance about whether management’s assertion about compliance with the specified requirements is fairly stated, in all material respects, and, accordingly, included examining, on a test basis, evidence about the Fund’s compliance with those requirements and performing such other procedures as we considered necessary in the circumstances. Included among our procedures were the following tests performed as of May 31, 2023 and with respect to agreement of purchases and sales of shares of beneficial interest of the underlying funds, for the period from April 30, 2023 (the date of our last examination), through May 31, 2023:

 

 

Confirmation of securities (the number of shares of beneficial interest of the underlying funds) owned by each Fund and held by Goldman Sachs & Co. LLC, a transfer agent that uses the book entry method of accounting for shares;

 

 

Reconciliation of all such securities (shares of beneficial interest of the underlying funds) to the books and records of each Fund and Goldman Sachs & Co. LLC; and

 

 

Agreement of a sample of purchases of shares of beneficial interest of the underlying funds and a sample of sales of shares of beneficial interest of the underlying funds by each Fund since our last report from the books and records of each Fund to confirmations received from Goldman Sachs & Co. LLC.

We believe that our examination provides, and that the evidence we obtained is sufficient and appropriate to provide, a reasonable basis for our opinion. Our examination does not provide a legal determination on each Fund’s compliance with specified requirements.

We are required to be independent and to meet our other ethical responsibilities in accordance with relevant ethical requirements related to the engagement.

In our opinion, management’s assertion that each of the series of Goldman Sachs Variable Insurance Trust (as set forth in the attached Schedule of Funds) complied with the requirements of subsections (b) and (c) of Rule 17f-2 of the Investment Company Act of 1940, as interpreted in management’s assertion as of May 31, 2023 with respect to shares of beneficial interest of the underlying funds owned by each Fund and held by Goldman Sachs & Co. LLC in book entry form, is fairly stated, in all material respects.

This report is intended solely for the information and use of management and the Board of Trustees of each Fund and the Securities and Exchange Commission and is not intended to be and should not be used by anyone other than these specified parties.

 

/s/ PricewaterhouseCoopers LLP
Boston, Massachusetts
November 16, 2023


Schedule of Funds

 

Fund
Goldman Sachs Buffered S&P 500 Fund - Jan/Jul
Goldman Sachs Buffered S&P 500 Fund - Mar/Sep
Goldman Sachs Buffered S&P 500 Fund - May/Nov
Goldman Sachs Core Fixed Income Fund
Goldman Sachs Trend Driven Allocation Fund
Goldman Sachs International Equity Insights Fund
Goldman Sachs Large Cap Value Fund
Goldman Sachs Mid Cap Growth Fund
Goldman Sachs Mid Cap Value Fund
Goldman Sachs Multi-Strategy Alternatives Portfolio
Goldman Sachs Small Cap Equity Insights Fund
Goldman Sachs Strategic Growth Fund
Goldman Sachs U.S. Equity Insights Fund


 

 

Goldman, Sachs & Co. LLC | 30 Hudson Street | Jersey City, NJ 07302                   
   Goldman   
   Sachs   

 

 

Management Statement Regarding Compliance with Certain Provisions of the Investment Company Act of 1940

We, as members of management of the funds listed in Appendix A, each a series of Goldman Sachs Variable Insurance Trust (each, a “Fund” and, together, the “Funds”), are responsible for complying with the requirements of subsections (b) and (c) of Rule 17f-2, Custody of Investments by Registered Management Investment Company, of the Investment Company Act of 1940 as interpreted, amended or modified based on SEC orders or SEC staff issued no-action guidance relevant to interests in underlying funds held by an affiliated transfer agent in book entry form (“Rule 17f-2”). We are also responsible for establishing and maintaining effective internal controls over compliance with those requirements. We have performed an evaluation of each Fund’s compliance with the requirements of Rule 17f-2 as of May 31, 2023 and from April 30, 2023 or, if a later date, the commencement of operations of a Fund through May 31, 2023.

Based on this evaluation, we assert that each Fund was in compliance with the requirements of Rule 17f-2 of the Investment Company Act of 1940 as of May 31, 2023, with respect to shares of beneficial interest of the underlying funds owned by each Fund and held by Goldman Sachs & Co. LLC in book entry form.

 

By:   /s/ Joseph F. DiMaria
  Joseph F. DiMaria
  Treasurer, Principal Financial Officer and Principal Accounting Officer of the Funds
 

Title

 

November 16, 2023

  Date

 

By:   /s/ Peter W. Fortner
  Peter W. Fortner
  Assistant Treasurer of the Funds
 

Title

 

November 16, 2023

  Date


Appendix A

 

Fund
Goldman Sachs Buffered S&P 500 Fund - Jan/Jul
Goldman Sachs Buffered S&P 500 Fund - Mar/Sep
Goldman Sachs Buffered S&P 500 Fund - May/Nov
Goldman Sachs Core Fixed Income Fund
Goldman Sachs Trend Driven Allocation Fund
Goldman Sachs International Equity Insights Fund
Goldman Sachs Large Cap Value Fund
Goldman Sachs Mid Cap Growth Fund
Goldman Sachs Mid Cap Value Fund
Goldman Sachs Multi-Strategy Alternatives Portfolio
Goldman Sachs Small Cap Equity Insights Fund
Goldman Sachs Strategic Growth Fund
Goldman Sachs U.S. Equity Insights Fund