Bingham McCutchen LLP
One Federal Street
Boston, MA 02110
February 13, 2009
VIA EDGAR
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Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, DC 20549
Re: Registration Statements on Form N-14
The Registrants Listed on the Attached Appendix A (each, a "Registrant")
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Ladies and Gentlemen:
On behalf of each of the Registrants, we are hereby filing eight combined
proxy and registration statements on Form N-14, with exhibits (the "Registration
Statements").
Each Registration Statement relates to a proposed Agreement and Plan of
Reorganization whereby substantially all of the assets of a series of Regions
Morgan Keegan Select Funds, a Massachusetts business trust, will be transferred
in a tax-free reorganization to the corresponding series of a Registrant, in
exchange for shares of the series of the Registrant. The table in attached
Appendix B indicates which series of Regions Morgan Keegan Select Funds
corresponds to which series of a Registrant.
Each Registration Statement is being filed pursuant to Rule 488 under the
Securities Act of 1933, as amended. It is proposed that each filing will become
effective on March 16, 2009 pursuant to Rule 488.
Please call the undersigned at (617) 951-8567 with any questions relating
to the filings.
Sincerely,
/s/ Paul B. Raymond
Paul B. Raymond
Appendix A
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Registrant File No.
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Pioneer Bond Fund 811-02864
Pioneer Fund 811-01466
Pioneer Mid Cap Value Fund 811-06106
Pioneer Money Market Trust 811-05099
Pioneer Series Trust I 811-21425
Pioneer Series Trust III 811-21664
Pioneer Series Trust IV 811-21781
Pioneer Short Term Income Fund 811-21558
Appendix B
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Series of Regions Morgan Keegan Select Funds Corresponding Series of the Registrant
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Regions Morgan Keegan Select Mid Cap Growth Fund Pioneer Mid Cap Growth Fund II
(a series of Pioneer Series Trust I)
Regions Morgan Keegan Select Growth Fund Pioneer Growth Fund
(a series of Pioneer Series Trust I)
Regions Morgan Keegan Select Core Equity Fund Pioneer Fund
(the sole series of Pioneer Fund)
Regions Morgan Keegan Select Mid Cap Value Fund Pioneer Mid Cap Value Fund
(the sole series of Pioneer Mid Cap Value Fund)
Regions Morgan Keegan Select Value Fund Pioneer Cullen Value Fund
(a series of Pioneer Series Trust III)
Regions Morgan Keegan Select Balanced Fund Pioneer Classic Balanced Fund
(a series of Pioneer Series Trust IV)
Regions Morgan Keegan Select Fixed Income Fund Pioneer Bond Fund
(the sole series of Pioneer Bond Fund)
Regions Morgan Keegan Select Limited Maturity Fixed Income Fund Pioneer Short Term Income Fund
(the sole series of Pioneer Short Term Income Fund)
Regions Morgan Keegan Select Intermediate Tax Exempt Bond Fund Pioneer Intermediate Tax Free Income Fund
(a series of Pioneer Series Trust I)
Regions Morgan Keegan Select Treasury Money Market Fund Pioneer Treasury Reserves Fund
(a series of Pioneer Series Trust IV)
Regions Morgan Keegan Select Money Market Fund Pioneer Cash Reserves Fund
(a series of Pioneer Money Market Trust)