BINGHAM McCUTCHEN LLP
ONE FEDERAL STREET
BOSTON, MASSACHUSETTS 02110
January 13, 2010
VIA EDGAR
Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, D.C. 20549
Re: Pioneer Money Market Trust (File No. 811-5099)
Pioneer Series Trust II (File No. 811-21460)
Pioneer Series Trust IV (File No. 811-21781)
Pioneer Variable Contracts Trust (File No. 811-08786)
Form N-SAR Filings
Ladies and Gentlemen:
This letter is to respond to comments we received on January 5, 2010
from Mr. Kevin Rupert of the Staff of the Securities and Exchange Commission
(the "Commission") regarding Form N-SAR filings made by each of Pioneer Money
Market Trust with respect to its series Pioneer Cash Reserves Fund, Pioneer
Series Trust II with respect to its series Pioneer Tax Free Money Market Fund,
Pioneer Series Trust IV with respect to its series Pioneer Institutional Money
Market Fund and Pioneer Treasury Reserves Fund, and Pioneer Variable Contracts
Trust with respect to its series Pioneer Money Market VCT Portfolio (each, a
"Registrant" and collectively, the "Registrants") for the Registrant's most
recent reporting period ended June 30, 2009 or July 31, 2009, as applicable.
1. Comment: The Staff noted that each of the following
Registrants reported in response to Item 74W of Form N-SAR
that the mark-to-market net asset value per share (to four
decimal places) of a series of the Registrant that is a money
market fund (as set forth below) was $1.0000 as of the end of
the Registrant's most recent reporting period:
Registrant Money Market Fund Reporting Period Annual/Semi-Annual
N-SAR
Pioneer Money Market Trust Pioneer Cash Reserves Fund June 30, 2009 Semi-Annual
Pioneer Series Trust II Pioneer Tax Free Money June 30, 2009 Semi-Annual
Market Fund
Pioneer Series Trust IV Pioneer Institutional July 31, 2009 Annual
Money Market Fund
The Staff questioned whether the responses to Item 74W noted
above were accurate to four decimal places. The Staff
requested that, if a Registrant's response to Item 74W for a
money market fund noted above was not accurate to four decimal
places for the Registrant's most recent reporting period, the
Registrant file an amended Form N-SAR to correct any such
responses by Wednesday, January 13, 2010.
The Staff requested that each Registrant for which the most
recent Form N-SAR filing was a semi-annual filing also confirm
that the responses to Item 74W for each of its series that is
a money market fund included in the Registrant's most recent
Form N-SAR filing and the Registrant's four prior Form N-SAR
filings were accurate to four decimal places, and requested
that each Registrant for which the most recent Form N-SAR
filing was an annual filing also confirm that the responses to
Item 74W for each of its series that is a money market fund
included in the Registrant's most recent Form N-SAR filing and
the Registrant's three prior Form N-SAR filings were accurate
to four decimal places. The Staff requested that the
Registrants file amended Forms N-SAR to correct any such
responses to Item 74W that were not accurate by Wednesday,
January 13, 2010.
Response:
A. Pioneer Money Market Trust
The Registrant has reviewed the responses to Item 74W with
respect to its series Pioneer Cash Reserves Fund included in
the Registrant's semi-annual Form N-SAR filing for the period
ended June 30, 2009, and the Registrant's four prior Form
N-SAR filings.
The Registrant is filing amended Forms N-SAR to correct the
responses to Item 74W with respect to its series Pioneer Cash
Reserves Fund for the periods indicated below:
Reporting Annual/Semi-Annual Response to Item 74W in Response to Item 74W in
Period N-SAR Initial Form N-SAR Filing Amended Form N-SAR Filing
June 30, 2009 Semi-Annual 1.0000 0.9992
December 31, Annual 1.0000 0.9995
2008
The Registrant confirms that the responses to Item 74W with
respect to its series Pioneer Cash Reserves Fund included in
the Registrant's semi-annual Form N-SAR filing for the period
ended June 30, 2008, the Registrant's annual Form N-SAR filing
for the period ended December 31, 2007, and the Registrant's
semi-annual Form N-SAR filing for the period ended June 30,
2007, were accurate to four decimal places.
B. Pioneer Series Trust II
The Registrant has reviewed the responses to Item 74W with
respect to its series Pioneer Tax Free Money Market Fund
included in the Registrant's semi-annual Form N-SAR filing for
the period ended June 30, 2009, and the Registrant's four
prior Form N-SAR filings.
The Registrant is filing amended Forms N-SAR to correct the
responses to Item 74W with respect to its series Pioneer Tax
Free Money Market Fund for the periods indicated below:
Reporting Annual/Semi-Annual Response to Item 74W in Response to Item 74W in
Period N-SAR Initial Form N-SAR Filing Amended Form N-SAR Filing
December 31, Annual 1.0000 0.9999
2008
June 30, 2008 Semi-Annual 1.0000 1.0001
June 30, 2007 Semi-Annual 1.0000 1.0001
The Registrant confirms that the responses to Item 74W with
respect to its series Pioneer Tax Free Money Market Fund
included in the Registrant's semi-annual Form N-SAR filing for
the period ended June 30, 2009, and the Registrant's annual
Form N-SAR filing for the period ended December 31, 2007, were
accurate to four decimal places.
C. Pioneer Series Trust IV
i. Pioneer Institutional Money Market Fund
The Registrant has reviewed the responses to Item 74W with
respect to its series Pioneer Institutional Money Market Fund
included in the Registrant's annual Form N-SAR filing for the
period ended July 31, 2009, and the Registrant's three prior
Form N-SAR filings.
The Registrant is filing amended Forms N-SAR to correct the
responses to Item 74W with respect to its series Pioneer
Institutional Money Market Fund for the periods indicated
below:
Reporting Annual/Semi-Annual Response to Item 74W in Response to Item 74W in
Period N-SAR Initial Form N-SAR Filing Amended Form N-SAR Filing
July 31, 2009 Annual 1.0000 1.0003
July 31, 2008 Annual 1.0000 0.9997
The Registrant confirms that the responses to Item 74W with
respect to its series Pioneer Institutional Money Market Fund
included in the Registrant's semi-annual Form N-SAR filing for
the period ended January 31, 2009, and the Registrant's
semi-annual Form N-SAR filing for the period ended January 31,
2008, were accurate to four decimal places.
ii. Pioneer Treasury Reserves Fund
The Registrant has reviewed the responses to Item 74W with
respect to its series Pioneer Treasury Reserves Fund included
in the Registrant's annual Form N-SAR filing for the period
ended July 31, 2009, and the Registrant's three prior Form
N-SAR filings.
The Registrant is filing amended an Form N-SAR to correct the
response to Item 74W with respect to its series Pioneer
Treasury Reserves Fund for the period indicated below:
Reporting Annual/Semi-Annual Response to Item 74W in Response to Item 74W in
Period N-SAR Initial Form N-SAR Filing Amended Form N-SAR Filing
July 31, 2008 Annual 1.0012 1.0018
The Registrant confirms that the responses to Item 74W with
respect to its series Pioneer Treasury Reserves Fund included
in the Registrant's annual Form N-SAR filing for the period
ended July 31, 2009, the Registrant's semi-annual Form N-SAR
filing for the period ended January 31, 2009, and the
Registrant's semi-annual Form N-SAR filing for the period
ended June 30, 2008, were accurate to four decimal places.
D. Pioneer Variable Contracts Trust
The Registrant has reviewed the responses to Item 74W with
respect to its series Pioneer Money Market VCT Portfolio
included in the Registrant's semi-annual Form N-SAR filing for
the period ended June 30, 2009, and the Registrant's four
prior Form N-SAR filings.
The Registrant is filing an amended Form N-SAR to correct the
response to Item 74W with respect to its series Pioneer Money
Market VCT Portfolio for the period indicated below:
Reporting Annual/Semi-Annual Response to Item 74W in Response to Item 74W in
Period N-SAR Initial Form N-SAR Filing Amended Form N-SAR Filing
June 30, 2008 Semi-Annual 0.9997 0.9999
The Registrant confirms that the responses to Item 74W with
respect to its series Pioneer Money Market VCT Portfolio
included in the Registrant's semi-annual Form N-SAR filing for
the period ended June 30, 2009, the Registrant's annual Form
N-SAR filing for the period ended December 31, 2008, the
Registrant's annual Form N-SAR filing for the period ended
December 31, 2007, and the Registrant's semi-annual Form N-SAR
filing for the period ended June 30, 2007, were accurate to
four decimal places.
2. Comment: The Staff requested that the Registrants provide a
letter to the Commission that includes certain "Tandy"
acknowledgments with the Registrants' response to the Staff's
comments.
Response: A Tandy representation letter executed in connection with the
filing of this response is attached hereto as Exhibit A.
Please call the undersigned at (617) 951-8760 or Jeremy Kantrowitz at
(617) 951-8458 with any questions.
Sincerely,
/s/ Toby R. Serkin
Toby R. Serkin