BINGHAM McCUTCHEN LLP
ONE FEDERAL STREET
BOSTON, MASSACHUSETTS 02110
January 10, 2014
VIA EDGAR
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Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, D.C. 20549
Re: Pioneer Series Trust V (File Nos. 333-129005; 811-21823)
Registration Statement on Form N-1A
Ladies and Gentlemen:
This letter is to respond to comments we received from Mr. Dominic
Minore of the Staff of the Division of Investment Management of the Securities
and Exchange Commission (the "Commission") regarding Post-Effective Amendment
No. 18 to the Registration Statement on Form N-1A of Pioneer Series Trust V
(the "Registrant") relating to Pioneer Absolute Return Bond Fund. Following are
the Staff's comments and the Registrant's responses thereto:
I. General Comment
1. Comment: The Staff asked that the Registrant provide a letter to the
Commission that includes certain "Tandy" acknowledgments with the
Registrant's 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.
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II. Comments Applicable to the Fund's Prospectus
A. Fees and Expenses
1. Comment: The Staff requested that the Registrant confirm that the Fund does
not intend to invest in other investment companies to the extent
that Acquired Fund Fees and Expenses will represent 0.01% or more
of the Fund's expenses during the next twelve months, and that any
expenses related to investments in other investment companies are
reflected in the Other Expenses line item.
Response: The Registrant confirms that the Fund does not intend to invest in
other investment companies to the extent that Acquired Fund Fees
and Expenses will represent 0.01% or more of the Fund's expenses
during the next twelve months, and that estimated expenses related
to investments in other investment companies are reflected in the
Other Expenses line item.
2. Comment: The Staff noted that the Registrant states that, with respect to
the expense limitation arrangement for the Fund, the arrangement
may be terminated for a class only by
agreement of the adviser and the Board of Trustees. The
Staff requested that the Registrant confirm in its response
that the Board of Trustees does not intend to terminate the
arrangement during the term indicated in the prospectus.
Response: The Registrant confirms that it has not been informed that
the Board of Trustees intends to terminate the contractual
expense limitation arrangement with respect to the Fund
during the term indicated in the prospectus.
B. Principal Investment Strategies
1. Comment: The Staff requested that the Registrant revise the
disclosure to clarify the extent to which the Fund may
invest across market capitalization ranges, industries and
market sectors. The Staff noted that to the extent the Fund
intends to focus on a particular market capitalization
range, industry or market sector, the Fund should identify
that focus and add appropriate risk disclosure.
Response: The Registrant has revised the disclosure to address the
Staff's comment.
2. Comment: The Staff suggested that the Registrant consider revising
the disclosure regarding duration to state:
"For example, if the Fund has a positive three year
duration, then, all other things being equal, the
Fund will decrease in value by three percent if
interest rates rise one percent, and increase in
value by three percent if interest rates fall by one
percent. In contrast, if the Fund has a negative
three year duration, then, all other things being
equal, the Fund will increase in value by three
percent if interest rates rise one percent and
decrease in value by three percent if interest rates
fall one percent."
Response: The Registrant has revised the disclosure to address the
Staff's comment.
3. Comment: The Staff suggested that the Registrant consider adding
disclosure to explain the difference between maturity and
duration.
Response: The Registrant has added disclosure to address the Staff's
comment.
4. Comment: The Staff requested that the Registrant include an
undertaking in its response to the Staff's comments that,
to the extent that the Fund's investments in any one region
or country represent a material percentage of the Fund's
assets, the Registrant will supplement the Fund's
prospectus to disclose the specific risks of investing in
such region or country.
Response: The Registrant undertakes that, to the extent that the
Fund's investments in any one region or country represent a
material percentage of the Fund's assets, the Registrant
will supplement the Fund's prospectus to disclose the
specific risks of investing in such region or country.
5. Comment: The Staff suggested that the Registrant consider adding a
separate risk factor pertaining to the Fund's investments
in synthetic collateralized debt obligations.
Response: The Registrant has added disclosure to address the Staff's
comment.
C. Related Account Performance
1. Comment: The Staff provided the following comments with respect to the
disclosure in the section titled "Related Account Performance:"
a. The Staff noted that in the disclosure regarding related account
performance, the Registrant states that "the Luxembourg UCITS Fund
is the only account managed by Pioneer with investment objectives,
policies, strategies and restrictions substantially similar to
those of the Fund." The Staff requested that the Registrant
(i) delete the phrase "and restrictions" from the disclosure to be
consistent with the Staff's no-action letter to Nicholas-Applegate
Mutual Funds (pub. Avail. August 6, 1996); (ii) revise the
disclosure to clarify that the Luxembourg UCITS Fund is the only
account or fund managed by Pioneer with investment objectives,
policies and strategies substantially similar to those of the
Fund; and (iii) confirm in its response that there are no other
accounts or funds managed by Pioneer with investment objectives,
policies and strategies substantially similar to those of the Fund.
b. The Staff requested that, to the extent that the Luxembourg UCITS
Fund's performance information shown in the prospectus is not
calculated using the standard methods of computation prescribed by
the Securities and Exchange Commission, the Registrant disclose
how such performance information was calculated.
c. The Staff requested that the Registrant identify the inception
date of the Luxembourg UCITS Fund's performance information.
d. The Staff requested that the Registrant add disclosure (i) stating
that the Luxembourg UCITS Fund's performance information reflects
the deduction of all actual fees and expenses that were charged to
the Luxembourg UCITS Fund, (ii) indicating whether such actual
fees and expenses were higher or lower than the Fund's fees and
expenses, and (iii) if the Luxembourg UCITS Fund's fees and
expenses were lower than the Fund's fees and expenses, stating
that the Luxembourg UCITS Fund's performance would have been lower
than that shown if it had been subject to the fees and expenses of
the Fund.
e. The Staff requested that the Registrant add a prominent statement
in all caps or bold immediately prior to the average annual total
returns table for the Luxembourg UCITS Fund stating that "the
following is not the performance of Pioneer Absolute Return Bond
Fund."
f. The Staff requested that the Registrant identify the benchmark
index to which the Luxembourg UCITS Fund's performance will be
compared and indicate in the Registrant's response letter why it
is appropriate to compare the Luxembourg UCITS Fund's performance
to such benchmark index.
Response: After further analysis, the Registrant has determined that neither
the Luxembourg UCITS Fund nor any other account or fund managed by
Pioneer has investment objectives, policies and strategies that
are substantially similar to those of the Fund. Accordingly, the
Registrant has deleted the disclosure referenced by the Staff.
Please call the undersigned at (617) 951-8458 or Toby Serkin at
(617) 951-8760 with any questions.
Sincerely,
/s/ Jeremy Kantrowitz
Jeremy Kantrowitz
cc: Terrence J. Cullen
Christopher J. Kelley
Roger P. Joseph
Toby R. Serkin