245 Summer Street

Fidelity® Investments

Boston, MA 02210

February 10, 2025

U.S. Securities & Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

RE: Variable Insurance Products Fund V (the trust): File Nos. 033-17704 and 811-05361 Strategic Income Portfolio (the fund(s)) Post-Effective Amendment No. 105

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Ladies and Gentlemen:

Pursuant to Rule 8b-16 under the Investment Company Act of 1940, as amended, Regulation S-T and Rule 485(a) under the Securities Act of 1933, as amended, (33 Act) transmitted herewith on behalf of the trust is Post-Effective Amendment No. 105 to the trust’s current effective Registration Statement on Form N-1A.  This transmission contains a conformed signature page, the manually signed original of which is maintained at the offices of the trust.

This filing contains the Prospectus(es) and Statement(s) of Additional Information for the fund(s) referenced above.

Pursuant to Rule 472 under the 33 Act, copies indicating modifications and editorial changes made since the filing of the last applicable Registration Statement for each fund’s Prospectus(es) and SAI(s) are filed herein.

This filing is being filed for the purpose of implementing certain disclosure changes in connection with recent amendments to Rule 35d-1 under the Investment Company Act of 1940, as amended.

Pursuant to Rule 485(a), the trust elects an effective date of April 30, 2025. We request your comments by March 21, 2025. Please note that certain charts and tabular information will be included in the applicable Prospectus(es) and Statement(s) of Additional Information in a subsequent amendment to the trust’s Registration Statement.

Please contact Renée Fuller at (603) 721-4221 with any questions or comments regarding this filing.

Sincerely,

/s/Renée Fuller

Renée Fuller

Shareholder Reporting