AB Funds
1345 Avenue of the Americas
New York, NY 10105
March 25, 2015
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Attention: Jason Fox
Re: In the matter of the following SEC Filings:
Fund Fiscal Year End
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AllianceBernstein Variable Products Series - Money Market Portfolio liquidated 4/27/2012
AB Cap Fund - US Strategic Research Portfolio liquidated 6/27/2013
AB Cap Fund - Emerging Markets Equity Portfolio liquidated 11/25/2013
AB Cap Fund - International Discovery Portfolio liquidated 10/09/2014
AB Bond Fund - Real Asset Strategy 10/31/2014
AB Bond Fund - Government Reserves Portfolio 4/30/2014
AllianceBernstein Global High Income Fund 3/31/2014
Dear Mr. Fox:
Enclosed are responses to the requests made during my phone conversation with
you on February 27, 2015.
We hereby acknowledge that (i) each Fund is responsible for the adequacy and
accuracy of the disclosures in this filing ; (ii) Staff comments or changes to
disclosures in response to Staff comments in the filing reviewed by the Staff do
not foreclose the SEC from taking any action with respect to the filing ; and
(iii) a Fund named in this filing may not assert Staff comments as a defense in
any proceedings initiated by the SEC or any person under the federal securities
laws of the United States.
If you have any questions regarding our response, please do not hesitate to call
me at 914.259.7740.
Sincerely,
/s/ Joseph Mantineo
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Joseph Mantineo
Treasurer and Chief Financial
Officer of each Fund
cc: Larry Cranch, AllianceBernstein L.P.
Phil Kirstein, Senior Officer of the Funds
Mark R. Manley, AllianceBernstein L.P.
Emilie Wrapp, AllianceBernstein L.P.
Stephen Laffey, AllianceBernstein L.P.
Vince Noto, AllianceBernstein L.P
Steve Woetzel, AllianceBernstein L.P.
Phyllis Clarke, AllianceBernstein L.P.
Comment #1:
AllianceBernstein Variable Products Series - Money Market Portfolio,
AllianceBernstein Cap Fund - US Strategic Research Portfolio, AllianceBernstein
Cap Fund - Emerging Markets Equity Portfolio, AllianceBernstein Cap Fund -
International Discovery Portfolio
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Under the EDGAR database, the [active/inactive] status of the portfolios is not
checked off.
Response #1:
With respect to each Portfolio, the [active/inactive] status will be checked off
under the EDGAR database.
Comment #2:
AllianceBernstein Bond Fund - Real Asset Strategy
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There was no annual or semi- annual report found on the AllianceBernstein
website.
Response #2:
The annual and semi-annual reports can be found under the fund's new name, AB
All Market Real Return Portfolio, effective December 12, 2014.
Comment #3:
AllianceBernstein Bond Fund - Government Reserves Portfolio
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There was no literature available on the AllianceBernstein website.
Response #3:
This fund is offered to private wealth management clients only. The literature
is located on the AllianceBernstein website under the Private Wealth Management
link.
Comment #4:
AllianceBernstein Global High Income Fund
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The inside cover of the annual report states AllianceBernstein publishes full
portfolio holdings for the Fund monthly at the AllianceBernstein website;
however, such holdings were not found on the AllianceBernstein website.
Response #4:
The sentence was inadvertently included on the inside cover page. It will be
removed in future reports.