Report of Independent Registered Public
Accounting Firm


To the Shareholders and
Board of Trustees of Harbor Funds

In planning and performing our audit of the
financial statements of Harbor Capital
Appreciation Fund, Harbor Large Cap Value
Fund, Harbor Mid Cap Fund, Harbor Mid
Cap Growth Fund, Harbor Mid Cap Value
Fund, Harbor Small Cap Growth Fund,
Harbor Small Cap Value Fund, Harbor
Strategic Growth Fund, Harbor Robeco
Emerging Markets Conservative Equities
Fund, Harbor Robeco Global Conservative
Equities Fund, Harbor Robeco International
Conservative Equities Fund, Harbor Robeco
US Conservative Equities Fund, Harbor
Robeco Emerging Markets Active Equities
Fund, Harbor Diversified International All
Cap Fund, Harbor Emerging Markets Equity
Fund, Harbor Focused International Fund,
Harbor Global Leaders Fund, Harbor
International Fund, Harbor International
Growth Fund, Harbor International Small
Cap Fund, Harbor Overseas Fund, Harbor
Bond Fund, Harbor Convertible Securities
Fund, Harbor Core Bond Fund, Harbor
High-Yield Bond Fund, Harbor Money
Market Fund, Harbor Target Retirement
Income Fund, Harbor Target Retirement
2020 Fund, Harbor Target Retirement 2025
Fund, Harbor Target Retirement 2030 Fund,
Harbor Target Retirement 2035 Fund,
Harbor Target Retirement 2040 Fund,
Harbor Target Retirement 2045 Fund,
Harbor Target Retirement 2050 Fund,
Harbor Target Retirement 2055 Fund, and
Harbor Target Retirement 2060 Fund
(collectively referred to as the "Funds"),
(thirty six of the funds constituting Harbor
Funds) as of and for the period ended
October 31, 2020, in accordance with the
standards of the Public Company
Accounting Oversight Board (United
States), we considered the Funds' 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 Funds' internal
control over financial reporting.
Accordingly, we express no such opinion.

The management of the Funds 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 fund'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 fund'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 fund; (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
fund are being made only in accordance
with authorizations of management and
trustees of the fund; and (3) provide
reasonable assurance regarding prevention
or timely detection of unauthorized
acquisition, use or disposition of a fund'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 Funds'
annual or interim financial statements will
not be prevented or detected on a timely
basis.

Our consideration of the Funds' 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 Funds' internal control
over financial reporting and their operation,
including controls over safeguarding
securities, that we consider to be a material
weakness as defined above as of October 31,
2020.

This report is intended solely for the
information and use of management and the
Board of Trustees of the Funds 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

Chicago, Illinois
December 21, 2020