SEC Cover Letter

On behalf of each of the Registrants, we enclose herewith pursuant to Rule 20a-1 under the Investment Company Act of 1940, as amended, and Rule 14a-6(a) under the Securities Exchange Act of 1934, as amended (the “1934 Act”), a preliminary copy of each of the letter to shareholders, notice of special meeting, joint proxy statement and form of proxy to be used in connection with the special meeting of shareholders of each of the Registrants, to be held on June 13, 2017.

The purpose of the meetings to which the enclosed materials relate is to solicit shareholder approval of the following proposals: (i) to approve a new management agreement with Pioneer Investment Management, Inc.; (ii) to elect Trustees; and (iii) to convert certain funds’ investment objective(s) from fundamental to non-fundamental.

Pursuant to Rule 14a-6(d) under the 1934 Act, definitive copies of the enclosed materials filed pursuant to Rule 14a-6(a) are intended to be released to shareholders on or about March 17, 2017.

Please note that Pioneer Variable Contracts Trust, a registrant in the Pioneer Funds fund complex, has separately filed preliminary proxy materials on February 28, 2017 with the Securities and Exchange Commission regarding the proposals discussed in the enclosed materials.

Please call the undersigned at (617) 951-8458 or Toby Serkin at (617) 951-8760 with any comments or questions relating to the filing.

Sincerely,

/s/ Jeremy Kantrowitz

Jeremy Kantrowitz