Delaware Group Income Funds
100 Independence, 610 Market Street
Philadelphia, Pennsylvania 19106-2354
Delaware Distributors, L.P.
100 Independence, 610 Market Street
Philadelphia, Pennsylvania 19106-2354
May 19, 2021
Filing Desk
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Attention: Jeff Long and Jaea Hahn
Re:
| Delaware Group Income Funds (Registrant) File No. 333-255170 File No. 811-02071 Registration Statement on Form N-14 and Request for Acceleration |
Dear Mr. Long and Ms. Hahn:
The above referenced Registration Statement on Form N-14, which was filed on May 19, 2021 (the “Registration Statement”), was filed with the Securities and Exchange Commission pursuant to the Securities Act of 1933, as amended, for the purpose of registering Class R6 shares of Delaware High-Yield Opportunities Fund (the “Acquiring Fund”), a series of the Registrant, that will be issued to shareholders of Macquarie High Yield Bond Portfolio, (the “Acquired Fund”), a series of Delaware Pooled Trust, in connection with a transfer of substantially all of the assets of the Acquired Fund to the Acquiring Fund, pursuant to an Agreement and Plan of Reorganization, a form of which was included in the Registration Statement.
On behalf of the above referenced Registrant and its principal underwriter, Delaware Distributors, L.P., and pursuant to the requirements of Rule 461 under the Securities Act of 1933, we respectfully request that the effectiveness of the Registrant’s Registration Statement on Form N-14 be accelerated to Thursday, May 20, 2021, or as soon as practicable thereafter. A definitive Prospectus/Proxy Statement will be filed and mailed to Acquired Fund shareholders shortly thereafter. It is our understanding that you have previously discussed the possible acceleration of the Registration Statement with Taylor Brody of Stradley Ronon Stevens & Young, LLP.
Please contact Taylor Brody at (215) 564-8071 if you have any questions or comments regarding this filing or the acceleration request.
Sincerely,
| | /s/ Shawn K. Lytle
| | /s/ Brett D. Wright
|
Name: Title:
| Shawn K. Lytle
President/Chief Executive Officer
Delaware Group Income Funds
| Name: Title:
| Brett D. Wright
President
Delaware Distributors, L.P.
|
