February 16, 2011
The Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Re: Staff Review of Pioneer Funds' Financial Statements
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Ladies and Gentlemen:
This letter is to respond to comments received on February 3, 2011 from Ms.
Cindy Rose of the Staff of the Securities and Exchange Commission (the
"Commission") in connection with the Staff's review of financial statements
filed by open-end and closed-end funds in the Pioneer family of funds ("Funds")
and certain related materials.
1. COMMENT: The Staff of the Commission requested that the Funds provide
certain "Tandy" acknowledgments with the Funds' response to the Staff's
comments.
RESPONSE: Each Fund acknowledges that, with respect to filings made by
the Funds with the Commission and reviewed by the Staff:
(a) the Fund is responsible for the adequacy and accuracy of the disclosure
in the filings;
(b) Staff comments or changes to disclosure in response to Staff comments in
the filings reviewed by the Staff do not foreclose the Commission from taking
any action with respect to the filings; and
(c) the Fund may not assert Staff comments as a defense in any proceeding
initiated by the Commission or any person under the federal securities laws of
the United States.
PIONEER FLOATING RATE TRUST, ANNUAL REPORT DATED 11/30/2009
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PIONEER DIVERSIFIED HIGH INCOME TRUST, ANNUAL REPORT DATED 4/30/2009
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2. COMMENT: The Staff noted that the annual reports and the accompanying
press releases issued by each Fund disclose that its distributions during the
applicable reporting period included returns of capital. However, the Staff
noted that such returns of capital are not separately identified in the twelve
month dividend history presented in the monthly fact sheets for such Funds, or
explicitly excluded from such twelve month dividend history.
RESPONSE: The monthly fact sheets for these Funds incorrectly labeled
amounts as "dividends" when these amounts should have been labeled
"distributions." Going forward, the terminology used in the monthly fact sheets
will match the terminology used in the annual reports and press releases.
Amounts in the fact sheets will be properly labeled as "distributions" and
footnote disclosure will be added to clarify that distributions may include a
return of capital.
PIONEER FUND, ANNUAL REPORT DATED 12/31/2009
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3. COMMENT: On page 9 of the annual report of this Fund, the Staff noted
that the Fund discloses a return of capital as a "non-taxable distribution" in
the "Distributions per Share" chart.
RESPONSE: Pioneer adopted the term "non-taxable distribution" to
attempt to match the language convention used by the Internal Revenue Service
for Form 1099-DIV. We believed that using the same terminology would further a
reader's understanding of the tax implications of the distribution. Pioneer will
include the term "Tax Return of Capital" to identify any such distributions in
the future.
PIONEER OAK RIDGE SMALL CAP GROWTH FUND, ANNUAL REPORT DATED 11/30/2010
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PIONEER GLOBAL AGGREGATE BOND FUND, ANNUAL REPORT DATED 10/31/2010
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4. COMMENT: The Staff noted that the Statements of Assets and
Liabilities for a number of the open-end Funds disclose a receivable titled "Due
from Pioneer Investment Management, Inc." (the "Adviser"). The Staff noted that
it considers such a receivable to be a loan from the Fund to the Adviser. The
Staff stated that the practice especially concerns the Staff when the receivable
is in a large amount or represents a significant portion of management fees.
RESPONSE: Pioneer seeks to clarify for the Staff the specific function
of the account "Due from Pioneer Investment Management, Inc."
This account contains the monthly accrual for any amounts that the Adviser
is required to pay to the Fund under contractual expense limitation
arrangements. Such arrangements may include fee waivers and/or expense
reimbursements. Any such accrual is calculated at month end and settled between
the Fund and the Adviser within 7 business days after month end, thus appearing
on the Statements of Assets and Liabilities due to the timing of the period end.
There are no excess balances being allowed to accrue over an extended period of
time such that a loan may be said to exist. Any balance in the account at
year-end is simply the most recent month's accrued waiver amount and is paid to
the Fund promptly.
To determine what a reasonable balance for this account might be, such
balance should be compared to the total amount of "Fees waived and expenses
reimbursed by Pioneer Investment Management, Inc." as found in the Statement of
Operations.
Due from PIM Annual Expense Waiver Ratio
Pioneer Global Aggregate Bond Fund $19,088 / $143,056 =
0.1334
Pioneer Oak Ridge Small Cap Growth Fund $157,340 / $1,349,945
= 0.1166
One would expect the balance to reflect approximately one month's (1/12th) worth
of the total year-end waiver amount. While the ratio for neither Fund is exactly
1/12th (0.08333) of the annual amounts, both ratios are reasonably close to that
baseline ratio when normal asset and expense fluctuations are taken into account
thus indicating that no excessive balances are being allowed to accumulate.
Please contact me directly at 617-422-4468 if you require any further
clarification.
Very truly yours,
/s/ Mark E. Bradley
Mark E. Bradley
Treasurer, Pioneer Funds