[LOGO] Amundi ASSET MANAGEMENT
March 10, 2023
VIA EDGAR
Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, D.C. 20549
Re: SEC Staff Sarbanes-Oxley Review of Pioneer Bond Fund Filings
Ladies and Gentlemen:
This letter is to respond to comments received on February 9, 2023 from
Ms. Lauren Hamilton of the Staff of the Securities and Exchange Commission (the
"Commission") in connection with the Staff's review of financial statements for
the fiscal year ended June 30, 2022 and other filings made by Pioneer Bond Fund
(the "Registrant"). Following are the Staff's comments and the Registrant's
responses thereto:
1. Comment: The Staff noted that investments in reinsurance sidecars represented 1.6% of the Fund's net
assets, and investments in insurance-linked securities as a whole represented 2.8% of the
Fund's net assets. The Staff requested that the Fund explain supplementally the accounting
treatment for such securities with reference to applicable accounting guidance.
Response: The Registrant notes that the Fund's investments in insurance-linked securities include
event-linked bonds, collateralized reinsurance, reinsurance side cars and industry loss
warranties. The Registrant notes that the Fund's investments in event-linked bonds are
presented in the financial statements in accordance with ASC 310-20, and the Fund's
investments in collateralized reinsurance, reinsurance side cars and industry loss warranties
are presented in the financial statements in accordance with ASC 320-10 and ASC
321-10-35-6. The Registrant notes that, as previously discussed with the Staff:
(i) event-linked bonds are presented as debt instruments in the financial statements, the
income from which is reported as interest income in the financial statements; and
(ii) collateralized reinsurance, reinsurance side cars and industry loss warranties represent
an ownership in an underlying entity and distribute income in a way that is representative of
a dividend distribution, and, accordingly, are presented as equity securities in the financial
statements.
The Registrant notes that event-linked bonds are identified in the financial statements as
restricted as to resale because they are Rule 144A securities, and collateralized reinsurance,
reinsurance side cars and industry loss warranties are identified in the financial statements
as restricted as to resale because they are acquired in private transactions.
The Registrant notes that event-linked bonds are traded on an exchange. Event-linked bonds are
generally valued using the bid price obtained from an independent third party pricing service,
and such valuations generally are characterized as Level 2 inputs in the fair value hierarchy
outlined in U.S. GAAP. The Registrant notes that the reported value of an event-linked bond
would generally be expected to fluctuate in accordance with market activity.
The Registrant notes that reinsurance sidecars, collateralized reinsurance investments and
industry loss warranties generally are valued at the price provided by an insurance
transformer based on a formula approved by the Fund's valuation designee, and such valuations
generally are characterized as Level 3 inputs in the fair value hierarchy outlined in U.S.
GAAP. The Registrant notes that the reported value of such instruments reflects, among other
things, the remaining term of the instrument. Although such instruments have stated maturities
ranging from three to five years, the risk period for the instruments (i.e., exposure to the
underlying event risk, such as a hurricane) is generally for one year. Once the risk period
ends, the principal of the instrument is returned to the Fund, essentially as a return of
capital, and the remaining reported value on the Schedule of Investments represents remaining
interest payments. Accordingly, reinsurance sidecars, collateralized reinsurance investments
and industry loss warranties reported in the Fund's financial statements that have maturity
dates in 2022, 2023 or 2024 generally have lower reported values relative to face amounts.
The Registrant notes that the reported value of all insurance-linked securities may also
reflect the occurrence of a storm or other "trigger event" and, accordingly, differences
between the face amount and reported value of an instrument may reflect the occurrence of such
a "trigger event."
2. Comment: The Staff noted that Note 5 to the Financial Statements states that the Fund has adopted a
distribution plan (the "Distribution Plan") pursuant to Rule 12b-1 under the Investment
Company Act of 1940, as amended (the "1940 Act"), and that, pursuant to the Distribution Plan,
the Fund pays the Distributor 0.50% of the average daily net assets attributable to Class R
shares for distribution services. The Staff noted that Note 5 further states that the Fund
also has adopted a separate service plan for Class R shares (the "Service Plan"), under which
the Fund is authorized to pay securities dealers, plan administrators or other service
organizations that agree to provide certain services to retirement plans or plan participants
holding shares of the Fund a service fee of up to 0.25% of the Fund's average daily net assets
attributable to Class R shares held
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by such plans. The Staff requested that the Fund explain supplementally why the "Distribution
and Service (12b-1) Fees" line item for Class R shares in the fee table included in the Fund's
prospectus dated November 1, 2022 shows a fee of 0.50% of average daily net assets rather than
0.75%.
Response: The Registrant notes that the "Distribution and Service (12b-1) Fees" line item for Class R
shares in the fee table included in the Fund's prospectus shows a fee of 0.50% of average
daily net assets because such fee represents the fee payable by Class R shares under the
Distribution Plan. The Registrant notes that, unlike the Distribution Plan, the Service Plan
is not a distribution plan adopted pursuant to Rule 12b-1. Payments under the Service Plan are
for administrative services, and not distribution-related activities. As set forth in the
prospectus, such administrative services for which payments may be provided under the Service
Plan include: acting as a shareholder of record, processing purchase and redemption orders,
maintaining participant account records and answering participant questions regarding the
Fund. Accordingly, fees paid by Class R shares under the Service Plan are included in the fee
table in the "Other Expenses" line item rather than the "Distribution and Service (12b-1)
Fees" line item in accordance with Instructions 3(b) and 3(c)(i) to Item 3 of Form N-1A.
3. Comment: The Staff noted that the Fund states in the Schedule of Investments that, during the fiscal
year ended June 30, 2022, the Fund engaged in cross trades with certain funds and accounts in
accordance with Rule 17a-7 under the 1940 Act. The Staff noted the Fund did not include the
disclosures with respect to such transactions required by ASC 850-10-50, specifically
regarding realized gains and losses on such transactions. The Staff requested that the
Registrant explain supplementally why such disclosures were not included and confirm that such
transactions were effected in accordance with Rule 17a-7, including appropriate oversight of
such transactions by the Board of Trustees of the Fund.
Response: The Registrant notes that it believes that the Rule 17a-7 cross trades referred to by the
Staff were disclosed in the Schedule of Investments in accordance with the requirements of ASC
850-10-50. The Registrant notes that disclosure regarding realized gains and losses on cross
trades was not included in the Schedule of Investments because the Fund did not record any
gains or losses in connection with such cross trades during the fiscal year ended June 30,
2022.
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The Registrant notes that, as disclosed in the Schedule of Investments, the Fund engaged in
purchases of securities in cross trade transactions, but did not sell securities in cross
trade transactions during such period. The Registrant confirms that in future filings it will
include a line item for realized gain and loss activity in connection with cross trade
transactions even if such activity is recorded as zero. The Registrant confirms that cross
trade transactions engaged in by the Fund during the fiscal year ended June 30, 2022 were
effected in accordance with Rule 17a-7 and the procedures then in effect with respect to Rule
17a-7 transactions adopted by the Fund's Board of Trustees. In accordance with such
procedures, such cross trade transactions were reported to the Board of Trustees of the Fund
as part of regular compliance reporting presented at Board meetings.
Please contact me directly at 617-422-4697 if you require any further
clarification.
Very truly yours,
/s/ Anthony J. Koenig, Jr.
_________________________________
Anthony J. Koenig, Jr.
Treasurer, Pioneer Funds
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