Morgan, Lewis & Bockius LLP
One Federal Street
Boston, MA 02110
February 28, 2017
VIA EDGAR
Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, D.C. 20549
| Re: | Registrants in the Pioneer Funds Fund Complex |
Listed on the Attached Appendix (each, a “Registrant”)
Ladies and Gentlemen:
On behalf of each of the Registrants, we enclose herewith pursuant toRule 20a-1 under the Investment Company Act of 1940, as amended, and Rule14a-6(a) under the Securities Exchange Act of 1934, as amended (the “1934 Act”), a preliminary copy of each of the letter to shareholders, notice of special meeting, joint proxy statement and form of proxy to be used in connection with the special meeting of shareholders of each of the Registrants, to be held on June 13, 2017.
The purpose of the meetings to which the enclosed materials relate is to solicit shareholder approval of the following proposals: (i) to approve a new management agreement with Pioneer Investment Management, Inc.; (ii) to elect Trustees; and (iii) to convert certain funds’ investment objective(s) from fundamental tonon-fundamental.
Pursuant to Rule14a-6(d) under the 1934 Act, definitive copies of the enclosed materials filed pursuant to Rule14a-6(a) are intended to be released to shareholders on or about March 17, 2017.
Please note that Pioneer Variable Contracts Trust, a registrant in the Pioneer Funds fund complex, has separately filed preliminary proxy materials on February 28, 2017 with the Securities and Exchange Commission regarding the proposals discussed in the enclosed materials.
Please call the undersigned at (617)951-8458 or Toby Serkin at (617)951-8760 with any comments or questions relating to the filing.
Sincerely, |
/s/ Jeremy Kantrowitz |
Jeremy Kantrowitz |
Appendix
Pioneer Asset Allocation Trust Pioneer Bond Fund Pioneer Diversified High Income Trust Pioneer Emerging Markets Fund Pioneer Equity Income Fund Pioneer Floating Rate Trust Pioneer Fund Pioneer High Income Trust Pioneer High Yield Fund Pioneer ILS Interval Fund Pioneer Mid Cap Value Fund Pioneer Money Market Trust Pioneer Municipal High Income Advantage Trust Pioneer Municipal High Income Trust Pioneer Real Estate Shares Pioneer Series Trust II Pioneer Series Trust III Pioneer Series Trust IV Pioneer Series Trust V Pioneer Series Trust VI Pioneer Series Trust VII Pioneer Series Trust VIII Pioneer Series Trust X Pioneer Series Trust XI Pioneer Series Trust XII Pioneer Short Term Income Fund Pioneer Strategic Income Fund | (File No.811-21569) (File No.811-02864) (FileNo. 811-22014) (File No.811-08448) (File No.811-08657) (FileNo. 811-21654) (File No.811-01466) (FileNo. 811-21043) (File No.811-09685) (FileNo. 811-22987) (File No.811-06106) (File No.811-05099) (FileNo. 811-21409) (FileNo. 811-21321) (File No.811-07870) (FileNo. 811-21460) (File No.811-21664) (FileNo. 811-21781) (File No.811-21823) (File No.811-21978) (File No.811-10395) (File No.811-07318) (FileNo. 811-21108) (File No.811-01835) (File No.811-08547) (File No.811-21558) (FileNo. 811-09223) |
