[logo] PIONEER Investments(R)
VIA EDGAR
October 7, 2016
Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, D.C. 20549
Re: SEC Staff Sarbanes-Oxley Review of Filings by Pioneer Series Trust V
Ladies and Gentlemen:
This letter is to respond to comments received on September 8, 2016 from Ms.
Lauren Hamilton of the Staff of the Securities and Exchange Commission (the
"Commission") in connection with the Staff's review of financial statements and
other filings made by Pioneer Series Trust V (the "Registrant").
A. Edgar system
1. Comment: The Staff requested that the Registrant explain in its response
why the status of Pioneer U.S. Corporate High Yield Fund is
shown as "active" in the Edgar system, although the fund
appears to be inactive.
Response: Pioneer U.S. Corporate High Yield Fund is shown as active in
the Edgar system because, on July 21, 2016, the Registrant
filed a post-effective amendment to its registration statement
on Form N-1A pursuant to Rule 485(a) under the Securities Act
of 1933, as amended, to register the Fund as a new series of
the Registrant.
B. Funds' website
1. Comment: The Staff noted that the expense ratios shown on the funds'
website reflect acquired fund fees and expenses in the gross
expense ratios for certain funds but not in the net expense
ratios for those funds. The Staff noted, as an example, the
expense ratios shown on the funds' website for Pioneer Global
Equity Fund (Class K gross: 0.99%, Class K net: 0.80%), as
compared to the expense ratios shown in Pioneer Global Equity
Fund's prospectus (Class K gross: 0.99%, Class K net:
0.84%). The Staff requested that the Registrant add disclosure
to the funds' website to clarify that the net expense ratios
shown do not reflect acquired fund fees and expenses.
Response: The Registrant confirms that it will add disclosure to the
fund's website to clarify that the net expense ratios shown do
not reflect acquired fund fees and expenses.
C. Management Discussion of Fund Performance ("MDFP")
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1. Comment: The Staff noted that the expense ratios disclosed in the MDFP
are from a fund's current prospectus. The Staff requested that
the Registrant add disclosure to the MDFP in future shareholder
reports referring the reader to the financial highlights for a
more current expense ratio.
Response: The Registrant confirms that future shareholder reports will
add disclosure in the MDFP referring the reader to the
financial highlights for a more current expense ratio.
2. Comment: The Staff noted that the prospectus for Pioneer Global Equity
Fund states that the minimum initial investment amount for
Class K shares of the fund is $5 million. The Staff requested
that the line graph for Class K shares in future shareholder
reports start at $5 million in accordance with Instruction 1(d)
of Item 27(b)(7) of Form N-1A.
Response: The Registrant confirms that in future shareholder reports the
line graph for Class K shares will start at $5 million in
accordance with Instruction 1(d) of Item 27(b)(7) of Form N-1A.
D. Schedule of Investments
1. Comment: The Staff requested that the schedule of investments included
in future Form N-CSR and N-Q filings include, for each variable
rate security: (i) a description of the reference rate and
spread; and (ii) either (a) the end of period interest rate for
the security or (b) a note to the schedule of investments that
includes the end of period interest rate for each reference
rate described in the schedule.
Response: The Registrant understands that disclosure similar to that
requested by the Staff was included in the proposed Investment
Company Modernization rule amendments. Accordingly, the
Registrant will consider making this disclosure in future
reports.
E. Notes to the Financial Statements
1. Comment: The Staff requested that the Registrant add a statement to the
notes to the financial statements included in future shareholder
reports stating that the funds follow the accounting and
reporting requirements for investment companies under FASB
Accounting Standards Codification Topic 946.
Response: The Registrant will add disclosure to the financial statements
included in future reports to address the Staff's comment.
F. Form 40-17G
1. Comment: The Staff noted that the most recent Form 40-17G filed by the
Registrant addressed the Registrant's fidelity bond coverage
for the period July 31, 2015 through July 31, 2016. The Staff
requested that the Registrant confirm in its response that the
funds currently have adequate fidelity bond coverage in
accordance with Rule 17g-1 under the Investment Company Act of
1940, as amended (the "1940 Act") and that the Registrant has
filed appropriate documentation of such coverage in accordance
with Rule 17g-1.
Response: The Registrant confirms that the funds currently have adequate
fidelity bond coverage in accordance with Rule 17g-1 under the
1940 Act and that the Registrant has filed appropriate
documentation of such coverage in accordance with Rule 17g-1. On
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September 19, 2016, the Registrant filed its most recent Form
40-17G for the period July 31, 2016 through July 31, 2017.
G. Semi-Annual Reports:
1. Comment: The Staff noted that the Registrant filed semi-annual reports
using Edgar code "N-CSR." The Staff requested that the
Registrant file future semi-annual reports using Edgar code
"N-CSRS" to indicate that such reports are semi-annual reports.
Response: The Registrant confirms it will file future semi-annual reports
using Edgar code "N-CSRS" to indicate that such reports are
semi-annual reports.
Please contact me directly at 617-422-4468 if you require any further
clarification.
Very truly yours,
/s/ Mark E. Bradley
--------------------
Mark E. Bradley
Treasurer, Pioneer Funds
cc: Michael Melnick
Christopher Frazier
Christopher Kelley
Thomas Reyes