GLOBAL MARKETS & INVESTMENT BANKING
4 WORLD FINANCIAL CENTER - 5TH FLOOR
[LOGO] Merrill Lynch NEW YORK, NEW YORK 10080
212-449-6500
March 8, 2005
Dominic Minore, Esq.
Securities and Exchange Commission
Division of Investment Management
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: Pioneer Floating Rate Trust (the "Fund")
Form N-2 Registration Statement No. 333-121930
Investment Company Act File No. 811-21654
Dear Mr. Minore:
Pursuant to Rule 460 of the General Rules and Regulations under the
Securities Act of 1933, as amended (the "Securities Act"), we, on behalf of the
several underwriters, wish to advise you that distribution of the amended
Registration Statement, Form N-2 as filed on March 8, 2005, and Preliminary
Prospectus dated March 7, 2005, will be distributed during the period March 8,
2005 through March 10, 2005, as follows: approximately 350 copies of the
Preliminary Prospectus and a limited number of Registration Statements have or
will be sent to underwriters, dealers and institutions.
In accordance with Rule 461 of the General Rules and Regulations under the
Securities Act of 1933, the undersigned, on behalf of the underwriters of the
offering of up to 3,130 auction market preferred shares of the Fund, Series M7,
3,125 auction market preferred shares of the Fund, Series W7, and 3,125 auction
market preferred shares of the Fund, Series TH7, hereby joins in the request of
the Fund for acceleration of the effective date of the above-named Registration
Statement so that it becomes effective at 10:00 a.m., Eastern Time on March 10,
2005, or as soon as possible thereafter.
Very truly yours,
MERRILL LYNCH & CO.
MERRILL LYNCH, PIERCE, FENNER & SMITH
INCORPORATED
/s/ Michele Allong
-------------------------------------
Name: Michele Allong
Title: Authorized Signatory