January 26, 2018
VIA EDGAR
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: Aberdeen Funds — Registration Statement on Form N-14
Ladies and Gentlemen:
On behalf of Aberdeen Funds (the “Trust”), I hereby transmit for filing with the Securities and Exchange Commission (the “SEC”) the Registrant’s Registration Statement on Form N-14 (the “Registration Statement” relating to the proposed acquisition by the (1) Aberdeen Dynamic Dividend Fund; (2) Aberdeen Global Infrastructure Fund; (3) Aberdeen High Yield Managed Duration Municipal Fund; (4) Aberdeen International Real Estate Equity Fund; (5) Aberdeen Realty Income & Growth Fund; (6) Aberdeen Income Builder Fund; (7) Aberdeen Ultra Short Municipal Income Fund (each as “Acquiring Fund” and collectively, the “Acquiring Funds”) of separate corresponding series of the Alpine Series Trust, Alpine Equity Trust and Alpine Income Trust as noted in the table below (each, a “Target Fund” and collectively, the “Target Funds”). The Target Funds are being established as shell series to acquire assets in contemplation of a fund reorganization transaction involving the acquisition by each of the Acquiring Funds:
Target Funds |
| Acquiring Funds |
Alpine Dynamic Dividend Fund |
| Aberdeen Dynamic Dividend Fund |
Alpine Rising Dividend Fund |
| Aberdeen Income Builder Fund |
Target Funds |
| Acquiring Funds |
Alpine Global Infrastructure Fund |
| Aberdeen Global Infrastructure Fund |
Alpine International Real Estate Equity Fund |
| Aberdeen International Real Estate Equity Fund |
Alpine Realty Income & Growth Fund |
| Aberdeen Realty Income & Growth Fund |
Target Funds |
| Acquiring Funds |
Alpine High Yield Managed Duration Municipal Fund |
| Aberdeen High Yield Managed Duration Municipal Fund |
Alpine Ultra Short Municipal Income Fund |
| Aberdeen Ultra Short Municipal Income Fund |
Aberdeen Asset Management Inc.
1735 Market Street, 32nd floor, Philadelphia PA 19103
Telephone: (215) 405-5700
Please do not hesitate to contact the undersigned at 215-405-5757 with any questions or comments concerning this filing.
| Sincerely, |
|
|
|
|
| /s/ Jennifer M. Rogers |
| Jennifer M. Rogers |
cc: Lucia Sitar, Aberdeen Asset Management Inc.
Elliot Gluck, Willkie Farr & Gallagher LLP