AllianceBernstein Funds
1345 Avenue of the Americas
New York, NY 10105
March 23, 2016
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Attention: Jacob Sandoval
Re: In the matter of the following SEC Filings:
Fiscal Year
Fund End
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AB Blended Style Series, Inc. - Alliance Global Blend Portfolio Liquidated
11.24.08
AB Global Thematic Growth Fund 7.31.15
AB Blended Style Series - AB 2000-2055 Retirement Strategies 8.31.15
AB Global Bond Fund 9.30.15
AB High Income Fund 10.31.15
AB Institutional Funds - AB Global Real Estate Investment Fund II 10.31.15
AB Unconstrained Bond Fund 10.31.15
Dear Mr. Sandoval:
Enclosed are responses to the requests made during our phone conversation with
you on February 5, 2016, which include a revised response to Comment #10.
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: 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:
AB Blended Style Series, Inc. - Alliance Global Blend Portfolio - EDGAR Database
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The Portfolio is liquidated but is still shown as active on the EDGAR database.
Please de-activate the Portfolio on EDGAR database.
Response #1:
The Adviser intends to maintain the registration of this Portfolio. For this
purpose, it remains on the EDGAR database and, if subsequently offered, its
registration statement will be updated.
Comment #2:
AB Blended Style Series, Inc. - AB 2000-2055 Retirement Strategies - Form N-CSR
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Are the Form N-CSR certification signatories comfortable signing the
certifications before the independent auditors' opinion date?
Response #2:
The Adviser will review and consider whether any changes are warranted for the
signing of the N-CSR certifications.
Comment #3:
AB Institutional Funds, Inc. - AB Global Real Estate
Investment Fund II - Form 24f-2
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Please explain why the Form 24f-2 was filed late, on March 18, 2015.
Response #3:
The Form 24f-2 was inadvertently filed under an incorrect CIK and was
subsequently corrected on March 18, 2015.
Comment #4:
AB High Income Fund - Form N-SAR
--------------------------------
Why was an amended Form N-SAR filed on January 2, 2015?
Response #4:
The purpose of this amended filing was to provide updated responses to questions
73(A) (1) and 73(B).
Comment #5:
AB Blended Style Series, Inc. - AB 2000-2055 Retirement Strategies - Form N-Q
-----------------------------------------------------------------------------
In accordance with Regulation S-X, Rule 12-14, an affiliated transaction table
is required for Form N-Q when appropriate.
Response #5:
All future Form N-Q filings will include such disclosure as appropriate.
Comment #6:
All Applicable Funds - Form N-CSR
---------------------------------
Have any funds executed trades under Rule 17a-7? If yes, please disclose the
existence of the policy for such transactions.
Response #6:
The funds are permitted to execute trades under Rule 17a-7 in accordance with
procedures approved by the board. The funds intend to include such disclosure
going forward.
Comment #7:
AB Global Thematic Growth Fund - Form N-CSR
-------------------------------------------
Disclose in the Statement of Operations if there was foreign capital gain taxes
outstanding.
Response #7:
The Fund disclosed outstanding foreign capital gain taxes parenthetically next
to the dividend incomes caption on the Statement of Operations.
Comment #8:
AB Global Thematic Growth Fund - N-CSR
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Disclose the impact to total returns resulting from the contribution from the
Adviser in the Financial Highlights.
Response #8:
The Fund will disclose any total returns impact resulting from contributions
from affiliates and/or non-affiliates in the Financial Highlights.
Comment #9:
AB Global Thematic Growth Fund - N-CSR
--------------------------------------
Under the Security Lending note, is the open security on loan subject to a
master lending agreement or other agreements that would require disclosure under
ASU 2011-11?
Response #9:
The Fund's securities lending transactions are not subject to a master lending
agreement or other agreements that would require disclosure under ASU 2011-11.
Such transactions are governed by the terms of a separate securities lending
agreement with the lending agent. The lending agent acts as an agent in lending
transactions with the borrower. The agent is the liable party to the securities
borrowers and is also obligated to indemnify the Fund in the case of default of
any securities borrowed.
Comment #10:
AB Global Thematic Growth Fund and Other Applicable Funds - Form N-CSR
----------------------------------------------------------------------
Under the Security Lending note, the Fund will invest cash collateral proceeds
in AB Exchange Reserves. Disclose any potential conflict of interest if the
investment vehicle has management fees.
Response #10:
The Adviser will review and consider adding disclosure regarding potential
conflicts of interest associated with investments of cash collateral in AB
Exchange Reserves in respect of its management fees.
Comment #11:
AB High Income Fund - N-CSR
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In light of Form N-1A, Rule 27(b) (7) (ii) (A), is using a blended benchmark
versus broad based benchmark appropriate for the "line graph"?
Response #11:
The Fund intends to show one of the component indexes in the line graph going
forward.
Comment #12:
AB Global Bond Fund - N-CSR
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For future reporting, please consider disclosing the interest rate calculation
methodology for variable rate securities in the Portfolio of Investments.
Response #12:
The Fund will include such disclosure in future filings as appropriate.
Comment #13:
AB Global Bond Fund - N-CSR
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Investments in OCL Opportunities Fund I and OCL Opportunities Fund II are
flagged as illiquid and fair valued in the Portfolio of Investments. Are the
securities also restricted? If so, disclose as such.
Response #13:
These securities are not restricted.
Comment #14:
AB Global Bond Fund - N-CSR
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Consider disclosure of ROCSOP adjustments in the Notes to Financial Statements.
Response #14:
The Adviser believes the current ROCSOP narrative disclosure is in conformity
under Section 7.184 of the AICPA Audit and Accounting Guide.