December 13, 2013

Sally Samuel, Senior Counsel

Securities and Exchange Commission

Division of Investment Management

Office of Insurance Products

100 F Street NE

Washington, DC 20549

RE: Post-Effective Amendment No. 19 to Registration Statement on Form N-1A

Allianz Variable Insurance Products Fund of Funds Trust (the “Trust”)

File Nos. 333-119867 and 811-21624

Dear Ms. Samuel:

Per our telephone conversation today, we confirm that the prospectus and SAI for the AZL MVP T. Rowe Price Capital Appreciation Fund will be dated December 13, 2013, or, if later, the date that the above-referenced registration statement is declared to be effective. Please let me know if you need any additional information.

Sincerely,

/s/ Erik Nelson

Erik Nelson

Chief Legal Officer

763/765-7453

Erik.Nelson@allianzlife.com

Allianz Investment Management LLC, 5701 Golden Hills Drive, Minneapolis, MN 55416-1297. www.allianzlife.com

Allianz Investment Management LLC is a registered investment adviser that is a wholly owned subsidiary of Allianz Life

Insurance Company of North America. This information is confidential and is intended only for the use of the individual(s)

and/or entity/entities named above. This information should not be copied, forwarded, or further disseminated.