EX-99.77D POLICIES 3 exhibit77d.txt POLICES AllianceBernstein Variable Products Series Fund, Inc. Exhibit 77D -- AllianceBernstein High Yield Portfolio 811-05398 Former Non-Fundamental Policies Revision to Investment Policy During the Reporting Period The Portfolio invests, under normal circumstances, at least 80% of its net assets in high yield fixed-income securities. The merged Portfolio will invest, under normal circumstances, at least 80% of its net assets in fixed- income securities. The merged Portfolio will be renamed the Intermediate Bond Portfolio. The Portfolio invests in a diversified mix of high yield, below investment grade fixed-income securities, known as ?junk bonds.? The Portfolio may invest up to 25% of its net assets in U.S. Dollar-denominated securities issued by non- U.S. entities and up to 20% of its net assets in non-U.S. Dollar-denominated securities of such issuers. The Portfolio expects to invest in readily marketable fixed-income securities. The Portfolio may invest in mortgage-related and other asset-backed securities, loan participations, inflation- protected securities, structured securities, variable, floating and inverse floating rate instruments, preferred stocks, and may use other investment techniques. The Portfolio may invest without limit in U.S. Dollar- denominated foreign fixed- income securities and may invest up to 25% of its assets in non-U.S. Dollar- denominated foreign fixed- income securities. These investments may include, in each case, developed and emerging market securities. -- AllianceBernstein Americas Government Income Portfolio Former Non-Fundamental Policies Revision to Investment Policy During the Reporting Period The Portfolio normally invests at least 80% of its net assets in fixed-income securities of issuers located in countries in North, Central, or South America and at least 80% of its net assets in government securities. Same as above. The Portfolio primarily invests in fixed-income securities issued or guaranteed by (i) the federal governments of the United States, Canada, and Mexico; (ii) government-related entities in the United States, Canada, and Mexico; and (iii) the provincial governments of Canada and Mexico. To the extent that its assets are not invested in Government Securities, the Portfolio may invest the balance of its net assets in investment grade fixed- income securities issued by, and denominated in the local currencies of, governments of countries located in Central and South America or any of their political subdivisions, agencies, instrumentalities or authorities, provided that such securities are denominated in their local currencies. The Portfolio limits its investments in fixed-income securities issued by the governmental entities of any one such country to 10% of its net assets. The Portfolio invests in investment grade securities denominated in the U.S. Dollar, the Canadian Dollar, and the Mexican Peso and expects to maintain at least 25% of its assets in U.S. Dollar denominated securities. Same as above. -- AllianceBernstein Global Dollar Government Portfolio Former Non-Fundamental Policies Revision to Investment Policy During the Reporting Period The Portfolio invests, under normal circumstances, at least 80% of its net assets in government obligations. Same as above. The Portfolio invests at least 65% of its net assets in interests in entities organized and operated solely for the purpose of restructuring the investment characteristics of sovereign debt obligations. The Portfolio?s investments in sovereign debt obligations will emphasize debt obligations issued by countries in the J.P. Morgan Emerging Markets Bond Index Global, which currently includes approximately 31 countries whose economies are concluded to be developing or emerging from underdevelopment. The Portfolio?s non-U.S. investments emphasize emerging markets and developing countries. The Portfolio limits its investments in the sovereign debt obligations of any one country to less than 25% of its net assets, although the Portfolio may invest up to 30% of its net assets in the sovereign debt obligations and corporate fixed-income securities of issuers in each of the countries that constitute part of the Portfolio?s focus, including Brazil, Mexico, the Philippines, Russia, Turkey and Venezuela. The Portfolio expects that it will not invest more than 10% of its net assets in any other single country outside the U.S. The Portfolio also may invest in U.S. and non-U.S. corporate fixed-income securities. The Portfolio?s investments in sovereign debt obligations and corporate debt securities are U.S. Dollar-denominated. The Portfolio invests substantially all of its assets in lower-rated securities or unrated securities of equivalent investment quality. The Portfolio also may invest in U.S. and non-U.S. corporate fixed-income securities. Same as above. -- AllianceBernstein Global Bond Portfolio Former Non-Fundamental Policies Revision to Investment Policy During the Reporting Period The Portfolio invests, under normal circumstances, at least 80% of its net assets in bonds and other fixed- income securities. Same as above. The Portfolio normally invests at least 65% of its net assets in fixed-income securities of at least three countries. The Portfolio invests in U.S. Government securities, securities issued by governments other than the U.S. Government or supranational organization debt securities, corporate debt obligations, and commercial paper of banks and bank holding companies. The Portfolio?s non-U.S. investments are generally denominated in currencies other than the U.S. Dollar. The Portfolio invests approximately 25% of its net assets in U.S. Dollar- denominated fixed-income securities. Same as above. -- AllianceBernstein U.S. Government/High Grade Securities Portfolio Former Non-Fundamental Policies Revision to Investment Policy During the Reporting Period The Portfolio invests, under normal circumstances, at least 80% of its net assets in U.S. Government or high- grade fixed-income securities rated A or better by S&P and Moody?s or equivalent rating. Same as above. The Portfolio?s investments include mortgage-backed securities and repurchase agreements relating to U.S. Government securities. U.S. Government securities in which the Portfolio invests may include a significant amount of securities issued by government-sponsored entities, such as the Federal National Mortgage Association, or FNMA, or the Federal Home Loan Mortgage Corporation, or FHLMC, which are neither issued nor guaranteed by the U.S. Government. The Portfolio may also invest in investment grade corporate and other debt securities. These include hybrid and structured debt instruments as well as U.S. Dollar-denominated securities issued by non-U.S. corporations and governments. Same as above. ablegal -1359971 v1