[Invesco Letterhead]
225 Liberty Street
New York, NY 10281
January 22, 2021
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Investment Management
Disclosure Review and Accounting Office
100 F Street NE
Washington, DC 20549
Re: | AIM Counselor Series Trust (Invesco Counselor Series Trust) (CIK: 0001112996) |
Ladies and Gentlemen:
On behalf of AIM Counselor Series Trust (Invesco Counselor Series Trust) (the “Registrant”), attached herewith for filing pursuant to the provisions of the Securities Act of 1933 (the “1933 Act”), including Rule 488 thereunder, is the electronic version of the Registrant’s Registration Statement on Form N-14 (the “Registration Statement”) containing a combined information statement/prospectus and related statement of additional information (“SAI”) to accomplish the following:
• | The title of the securities being registered are Class A, Class C, Class R, Class R5, Class R6 and Class Y shares of beneficial interest, without par value, of the Invesco Senior Floating Rate Fund, a series of the Registrant. |
Pursuant to Rule 488 under the 1933 Act, the Registrant hereby proposes that the Registration Statement becomes effective on February 22, 2021. The Registrant has previously registered an indefinite number of its shares under the 1933 Act pursuant to an election under Rule 24f-2 of the Investment Company Act of 1940.
Please be advised that concurrent with this filing, AIM Growth Series (Invesco Growth Series) and AIM Investment Funds (Invesco Investment Funds) have each filed a registration statement on Form N-14 which contains the same combined information statement/prospectus and SAI.
Please contact Jacqueline Edwards, Esq. of Stradley Ronon at (212) 812-4142 with respect to this Form N-14 or in her absence, contact me at (212) 652-4208.
Very truly yours,
/s/ Taylor V. Edwards |
Taylor V. Edwards, Esq. |
Associate General Counsel |
cc: Jaea Hahn