[Logo of Amundi Pioneer]
VIA EDGAR
April 30, 2020
Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, D.C. 20549
Re: SEC Staff Sarbanes-Oxley Review of Filings by Pioneer Funds
Ladies and Gentlemen:
This letter is to respond to comments received on April 1, 2020 from
Ms. Megan Miller of the Staff of the Securities and Exchange Commission in
connection with the Staff's review of the financial statements and other
filings by the Pioneer Funds listed on Appendix A (each, a "Registrant").
1. Comment: The Staff noted that Pioneer Mid Cap Value Fund invests in certain
real estate investment trusts (REITs). The Staff requested that
the Fund consider adding disclosure to the notes to the financial
statements stating that distributions received from REITs may be
classified as dividends, capital gains and/or return of capital.
Response: Pioneer Mid Cap Value Fund will add disclosure to future filings
of the Fund's financial statements describing the characteristics
of REIT distributions.
2. Comment: The Staff noted that the notes to the financial statements for
Pioneer Solutions - Balanced Fund indicate that the Fund is the
only series of Pioneer Asset Allocation Trust. The Staff noted,
however, that additional series of Pioneer Asset Allocation Trust
are shown as "active" in the Edgar system. The Staff requested
that Pioneer Asset Allocation Trust update the series information
on the Edgar system, as appropriate.
Response: Pioneer Asset Allocation Trust will update the series information
on the Edgar system.
3. Comment: The Staff noted that the table regarding Transactions in
Underlying Funds included in note 5 to the financial statements of
Pioneer Solutions - Balanced Fund does not appear to be consistent
with the requirements of Regulation S-X, Rule 12-14, Footnotes 1
and 4. The Staff requested that the Fund update the disclosure in
future filings.
Response: Pioneer Solutions - Balanced Fund will update the disclosure in
note 5 to the financial statements in future filings to be
consistent with the requirements of Regulation S-X, Rule 12-14.
4. Comment: The Staff noted that Pioneer Short Term Income Fund invests in
certain futures contracts and requested that the Fund consider
adding disclosure regarding futures to the principal investment
strategy disclosure in the Fund's prospectus in light of such
investments.
Response: Pioneer Short Term Income Fund will add disclosure to the
principal investment strategy disclosure in the Fund's prospectus
with respect to investments in futures contracts in connection
with the next annual update to the Fund's registration statement.
5. Comment: The Staff requested that each of Pioneer Dynamic Credit Fund and
Pioneer Strategic Income Fund consider enhancing the disclosure in
the notes to the financial statements that a distribution in
excess of earnings and profits may be a return of capital. The
Staff requested that each Fund also consider adding disclosure to
its prospectus indicating that a portion of a distribution from
the Fund may be a nontaxable return of capital.
Response: Each of Pioneer Dynamic Credit Fund and Pioneer Strategic Income
Fund will update the notes to financial statements in future
filings to indicate that the Fund does not consider the effect of
foreign currency gain/loss when calculating its monthly
distribution due to its unpredictable nature over the course of a
year and differing treatment for book and tax purposes. As a
result, the Fund may report a distribution in excess of its
earnings and profits or a tax return of capital at its fiscal year
end. Each Fund will add similar disclosure to the Fund's
prospectus in connection with the next annual update to the Fund's
registration statement.
6. Comment: The Staff requested that, for Funds that paid a return of capital,
please explain if the Funds considered the requirement in Item
27(b)(7)(iii) of Form N-1A to include in the Management's
Discussion of Fund Performance ("MDFP") a discussion of the extent
to which the Fund's distribution policy resulted in distributions
of capital.
Response: Each Fund notes that any distribution of capital was not as a
result of any policy or practice of maintaining a specified level
of distribution to shareholders or other distribution policy.
Rather, as noted in response to Comment 5, to the extent a Fund
made a distribution in excess of its earnings and profits or a tax
return of capital at its fiscal year end, such distribution
occurred because the Fund does not consider the effects of foreign
currency gain/loss when calculating its monthly distribution due
to its unpredictable nature over the course of a year and
differing treatment for book and tax purposes. However, each Fund
that pays a return of capital in the future will include in its
MDFP a discussion of the extent to which the Fund's distribution
policy resulted in distributions of capital.
7. Comment: The Staff noted that Item C.2.c of Form N-CEN for Pioneer
Strategic Income Fund indicates that a class of shares of the Fund
was terminated during the most recent reporting period. The Staff
requested that the Fund confirm that this is accurate and, if not,
to please correct the Item in a future Form N-CEN filing.
Response: Pioneer Strategic Income Fund confirms that it reported the
termination of the Fund's Class T shares in Item C.2.c of Form
N-CEN. Class T shares of the Fund were registered but did not
commence operations.
8. Comment: The Staff requested that each Fund disclose in the notes to the
financial statements the frequency with which payments of the
Fund's management fee are made to the adviser.
Response: Each Fund will disclose in the notes to the financial statements
in future filings the frequency with which payments of the Fund's
management fee are made to the adviser.
9. Comment: The Staff requested that the Funds explain in their response the
frequency that the "Due from the Adviser" account noted on the
statement of assets and liabilities for each Fund is settled, and
confirm whether the settlement terms for such account are the same
terms as for the "Due to affiliates" account.
Response: The Funds confirm that the "Due from the Adviser" account settles
monthly and has the same settlement terms as the "Due to
affiliates" account.
10.Comment: The Staff noted that Pioneer Diversified High Income Trust
compared its performance to the performance of a composite
benchmark in the MDFP included in its shareholder report. The
Staff requested that, to the extent that the Fund includes an MDFP
in future shareholder reports, the Fund compare its performance to
an appropriate broad-based securities market index.
Response: The Pioneer Diversified High Income Trust confirms that, to the
extent that the Fund includes an MDFP in future shareholder
reports, the Fund will compare its performance to an appropriate
broad-based securities market index.
11.Comment: The Staff noted that dividends paid to VMTP shareholders of
Pioneer Municipal High Income Advantage Trust and Pioneer
Municipal High Income Trust are not reflected in the expense
ratios in the financial highlights or as expenses in the
statements of operations. The Staff noted that it has issued
guidance with respect to disclosure regarding payments to
preferred shareholders (see Dear CFO Letters 1997-05 and 1997-06),
and requested that the Funds explain why the presentation in the
financial statements is not consistent with the Staff's guidance.
Response: Pioneer Municipal High Income Advantage Trust and Pioneer
Municipal High Income Trust will update its statement of
operations and financial highlights in future filings to account
for dividends paid to VMTP shareholders in accordance with the
guidance set forth in the relevant Dear CFO Letters.
Please contact me directly at 617-422-4468 if you require any further
clarification.
Very truly yours,
Mark E. Bradley
Treasurer, Pioneer Funds
cc: Michael Melnick
Christopher Frazier
Christopher Kelley
Thomas Reyes
Appendix A
Pioneer Funds Reviewed
Date of
Financial
Statements
CIK Reviewed File No Fund Name Registrant Name
--- ---------- --------- ----------------------------------------- ---------------------------------
S000003948 10/31/19 811-08657 Pioneer Equity Income Fund Pioneer Equity Income Fund
S000028857 10/31/19 811-21978 Pioneer Flexible Opportunities Fund Pioneer Series Trust VI
S000015510 10/31/19 811-21978 Pioneer Floating Rate Fund Pioneer Series Trust VI
S000010203 10/31/19 811-10395 Pioneer Global High Yield Fund Pioneer Series Trust VII
S000019711 10/31/19 811-10395 Pioneer Global Multisector Income Fund Pioneer Series Trust VII
S000003994 10/31/19 811-09685 Pioneer High Yield Fund Pioneer High Yield Fund
S000004143 10/31/19 811-06106 Pioneer Mid Cap Value Fund Pioneer Mid Cap Value Fund
S000004011 11/30/19 811-07318 Pioneer International Equity Fund Pioneer Series Trust VIII
S000010084 11/30/19 811-21460 Pioneer Select Mid Cap Growth Fund Pioneer Series Trust II
S000003991 12/31/19 811-01466 Pioneer Fund Pioneer Fund
Pioneer U.S. Government Money Market
S000009919 12/31/19 811-05099 Fund Pioneer Money Market Trust
S000010000 12/31/19 811-07870 Pioneer Real Estate Shares Pioneer Real Estate Shares
S000010085 12/31/19 811-21460 Pioneer AMT-Free Municipal Fund Pioneer Series Trust II
S000010136 12/31/19 811-01835 Pioneer Core Equity Fund Pioneer Series Trust XI
S000010172 12/31/19 811-08786 Pioneer Bond VCT Portfolio Pioneer Variable Contracts Trust
S000010180 12/31/19 811-08786 Pioneer Emerging Markets VCT Portfolio Pioneer Variable Contracts Trust
S000010181 12/31/19 811-08786 Pioneer Equity Income VCT Portfolio Pioneer Variable Contracts Trust
S000010159 12/31/19 811-08786 Pioneer Fund VCT Portfolio Pioneer Variable Contracts Trust
S000010184 12/31/19 811-08786 Pioneer High Yield VCT Portfolio Pioneer Variable Contracts Trust
S000010186 12/31/19 811-08786 Pioneer Mid Cap Value VCT Portfolio Pioneer Variable Contracts Trust
S000010160 12/31/19 811-08786 Pioneer Real Estate Shares VCT Portfolio Pioneer Variable Contracts Trust
Pioneer Select Mid Cap Growth VCT
S000010170 12/31/19 811-08786 Portfolio Pioneer Variable Contracts Trust
S000010163 12/31/19 811-08786 Pioneer Strategic Income VCT Portfolio Pioneer Variable Contracts Trust
S000031914 3/31/19 811-21108 Pioneer Dynamic Credit Fund Pioneer Series Trust X
S000004137 3/31/19 811-21108 Pioneer Fundamental Growth Fund Pioneer Series Trust X
S000031915 Pioneer Multi-Asset Ultrashort Income
3/31/19 811-21108 Fund Pioneer Series Trust X
S000003927 6/30/19 811-02864 Pioneer Bond Fund Pioneer Bond Fund
Pioneer Balanced ESG Fund (formerly,
S000010109 7/31/19 811-21781 Pioneer Classic Balanced Fund) Pioneer Series Trust IV
S000035110 7/31/19 811-21781 Pioneer Multi-Asset Income Fund Pioneer Series Trust IV
S000004007 7/31/19 811-21569 Pioneer Solutions - Balanced Fund Pioneer Asset Allocation Trust
S000004009 8/31/19 811-08547 Pioneer Disciplined Growth Fund Pioneer Series Trust XII
S000010093 8/31/19 811-21664 Pioneer Disciplined Value Fund Pioneer Series Trust III
S000010228 8/31/19 811-21558 Pioneer Short Term Income Fund Pioneer Short Term Income Fund
S000010131 9/30/19 811-09223 Pioneer Strategic Income Fund Pioneer Series Trust XIV
CEF 4/30/2019 811-22014 Pioneer Diversified High Income Trust Pioneer Diversified High Income Trust
CEF 11/30/2019 811-21654 Pioneer Floating Rate Trust Pioneer Floating Rate Trust
CEF 3/31/2019 811-21043 Pioneer High Income Trust Pioneer High Income Trust
Pioneer Municipal High Income Pioneer Municipal High Income Advantage
CEF 3/31/2019 811-21409 Advantage Trust Trust
CEF 4/30/2019 811-21321 Pioneer Municipal High Income Trust Pioneer Municipal High Income Trust