[LOGO - AMUNDI US]
September 23, 2022
VIA EDGAR
Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, D.C. 20549
Re: SEC Staff Review of Filings by Pioneer Funds
Ladies and Gentlemen:
This letter is to respond to comments we received from Mr. Kenneth Ellington
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"). Following are the Staff's
comments and the Registrant's responses thereto:
1. Comment: The Staff noted that each closed-end Fund Registrant
identifies certain securities as being in default on the
Fund's Schedule of Investments, but that these securities are
not marked as non-income producing. The Staff requested that
the Registrants explain this presentation in their response.
Response: Each closed-end Fund Registrant notes that the Fund identifies
certain securities as being in default on the Fund's Schedule
of Investments because such securities are not paying their
full coupon. However, such securities are currently making
distributions. Accordingly, such securities are not marked as
non-income producing on the Fund's Schedule of Investments.
2. Comment: The Staff noted that, according to the Statement of Changes in
Net Assets of Pioneer Corporate High Yield Fund, the Fund had
a significant return of capital distribution during the most
recent fiscal year. The Staff requested that the Registrant
explain in its response why the historical distribution chart
on the Fund's website does not include this return of capital
distribution as reflected in the Fund's financial statements.
Response: The Registrant confirms that it will update the historical
distribution chart on the website of Pioneer Corporate High
Yield Fund to include the return of capital distribution as
reflected in the Fund's financial statements.
3. Comment: The Staff noted that each Registrant's filings on Form N-CSR
refers to the "second fiscal quarter of the period covered by
the report" for the disclosure related to Form N-CSR Item
11(b). The Staff requested that each Registrant utilize the
language provided in Form N-CSR Item 11(b) in future filings,
which refers to "the period covered by the report" not
isolated to a particular quarter, and that each Registrant
confirm in its
response that, with respect to the Registrant's Form N-CSR
filing listed on Appendix A, there were no changes in the
Registrant's internal control over financial reporting that
occurred during the period covered by the report.
Response: Each Registrant confirms that it will utilize the language
provided in Form N-CSR Item 11(b) in future filings. Each
Registrant confirms that, with respect to the Registrant's
Form N-CSR filing listed on Appendix A, there were no changes
in the Registrant's internal control over financial reporting
that occurred during the period covered by the report.
4. Comment: The Staff noted that Pioneer ILS Bridge Fund has never filed
Form N-PX and requested that the Fund correct this issue as
soon as possible.
Response: Pioneer ILS Bridge Fund notes that the Fund has not commenced
operations and, accordingly, there has been no proxy voting
activity for the Fund since the Fund's registration statement
became effective. Pioneer ILS Bridge Fund confirms that it has
filed Form N-PX for each reporting period since the Fund's
registration statement became effective.
Please contact me directly at 617-422-4697 if you require any further
clarification.
Very truly yours,
/s/ Anthony J. Koenig, Jr.
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Anthony J. Koenig, Jr.
Treasurer, Pioneer Funds
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Appendix A
Pioneer Funds Reviewed
FYE
File # Registrant Name Series Name Reviewed
811-21043 Pioneer High Income Fund, Pioneer High Income Fund, 3/31/2022
Inc. Inc.
811-21108 Pioneer Series Trust X Pioneer Multi-Asset 3/31/2022
Ultrashort Income Fund
811-21108 Pioneer Series Trust X Pioneer Corporate High 8/31/2021
Yield Fund
811-21108 Pioneer Series Trust X Pioneer Fundamental Growth 3/31/2022
Fund
811-21321 Pioneer Municipal High Pioneer Municipal High 4/30/2022
Income Fund, Inc. Income Fund, Inc.
811-21409 Pioneer Municipal High Pioneer Municipal High 3/31/2022
Income Advantage Fund, Inc. Income Advantage Fund, Inc.
811-21823 Pioneer Series Trust V Pioneer Corporate High 8/31/2018
Yield Fund
811-21823 Pioneer Series Trust V Pioneer Global Equity Fund 8/31/2021
811-21823 Pioneer Series Trust V Pioneer High Income 8/31/2021
Municipal Fund
811-22014 Pioneer Diversified High Pioneer Diversified High 4/30/2022
Income Fund, Inc. Income Fund, Inc.
811-23172 Pioneer ILS Bridge Fund Pioneer ILS Bridge Fund --
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