Report of Independent Registered Public
Accounting Firm
To the Shareholders and
Board of Trustees of American Beacon Funds
In planning and performing our audits of the
financial statements of American Beacon Funds
(comprised of American Beacon AHL Managed
Futures Strategy Fund, American Beacon AHL
Target Risk Fund, American Beacon Bahl &
Gaynor Small Cap Growth Fund, American
Beacon Bridgeway Large Cap Growth Fund,
American Beacon Bridgeway Large Cap Value
Fund, American Beacon Stephens Mid-Cap
Growth Fund, and American Beacon Stephens
Small Cap Growth Fund) (the Trust) as of and
for the periods ended December 31, 2019, in
accordance with the standards of the Public
Company Accounting Oversight Board (United
States), we considered the Trust's internal
control over financial reporting, including
controls over safeguarding securities, as a
basis for designing our auditing procedures for
the purpose of expressing our opinion on the
financial statements and to comply with the
requirements of Form N-CEN, but not for the
purpose of expressing an opinion on the
effectiveness of the Trust's internal control over
financial reporting. Accordingly, we express no
such opinion.
The management of the Trust is responsible for
establishing and maintaining effective internal
control over financial reporting. In fulfilling this
responsibility, estimates and judgments by
management are required to assess the
expected benefits and related costs of controls.
A trust's internal control over financial reporting
is a process designed to provide reasonable
assurance regarding the reliability of financial
reporting and the preparation of financial
statements for external purposes in accordance
with U.S. generally accepted accounting
principles. A trust's internal control over
financial reporting includes those policies and
procedures that (1) pertain to the maintenance
of records that, in reasonable detail, accurately
and fairly reflect the transactions and
dispositions of the assets of the trust; (2)
provide reasonable assurance that transactions
are recorded as necessary to permit
preparation of financial statements in
accordance with U.S. generally accepted
accounting principles, and that receipts and
expenditures of the trust are being made only in
accordance with authorizations of management
and trustees of the trust; and (3) provide
reasonable assurance regarding prevention or
timely detection of unauthorized acquisition,
use or disposition of a trust's assets that could
have a material effect on the financial
statements.
Because of its inherent limitations, internal
control over financial reporting may not prevent
or detect misstatements. Also, projections of
any evaluation of effectiveness to future periods
are subject to the risk that controls may become
inadequate because of changes in conditions,
or that the degree of compliance with the
policies or procedures may deteriorate.
A deficiency in internal control over financial
reporting exists when the design or operation of
a control does not allow management or
employees, in the normal course of performing
their assigned functions, to prevent or detect
misstatements on a timely basis. A material
weakness is a deficiency, or a combination of
deficiencies, in internal control over financial
reporting, such that there is a reasonable
possibility that a material misstatement of the
Trust's annual or interim financial statements
will not be prevented or detected on a timely
basis.
Our consideration of the Trust's internal control
over financial reporting was for the limited
purpose described in the first paragraph and
would not necessarily disclose all deficiencies
in internal control that might be material
weaknesses under standards established by
the Public Company Accounting Oversight
Board (United States). However, we noted no
deficiencies in the Trust's internal control over
financial reporting and its operation, including
controls over safeguarding securities, that we
consider to be a material weakness as defined
above as of December 31, 2019.
This report is intended solely for the information
and use of management and the Board of
Trustees of the Trust and the Securities and
Exchange Commission and is not intended to
be and should not be used by anyone other
than these specified parties.

/s/ Ernst & Young LLP

Dallas, Texas
February 28, 2020