American Funds Insurance Series

333 South Hope Street

Los Angeles, California  90071-1406

Phone (213) 486 9447

Fax (213) 486 9455

E-mail: siik@capgroup.com

Steven I. Koszalka

Secretary

April 28, 2011

Document Control

Division of Investment Management

Securities and Exchange Commission

Office of Insurance Products

100 F Street, NE

Washington, DC 20549

Re:	American Funds Insurance Series
	File No. 002-86838 and No. 811-03857

Dear Sir or Madam:

Attached is Form N-1A of the above-named investment company, which includes Post-Effective Amendment No. 53 to the Registration Statement under the Securities Act of 1933 and Amendment No. 53 to the Registration Statement under the Investment Company Act of 1940, as amended.  The prospectuses and Statement of Additional Information have been marked to show changes from the previous filing.

It is proposed that this registration statement become automatically effective on May 1, 2011 pursuant to paragraph (b) of rule 485.

Sincerely,

/s/ Steven I. Koszalka

Steven I. Koszalka

Attachment

cc:	Alison T. White
	Division of Investment Management –
	Office of Insurance Products