CORRESP

                           PIONEER FLOATING RATE TRUST
                                 60 State Street
                                Boston, MA 02109

                                 (617) 742-7825


December 20, 2004

VIA ELECTRONIC SUBMISSION

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

Re:      Pioneer Floating Rate Trust
         Request for acceleration of effective date of
         Registration Statement on Form N-2
         (File Nos. 333-119731 and 811-21654)        _


Ladies and Gentlemen:

Pursuant to Rule 461 of Regulation C under the Securities  Act of 1933,  Pioneer
Floating Rate Trust (the  "Registrant")  hereby requests that the effective date
of the Registrant's  Registration  Statement on Form N-2 (File Nos.  333-119731;
811-21654) be accelerated  to 2:00 p.m.  (Eastern time) on December 22, 2004, or
as soon thereafter as possible.



                             PIONEER FLOATING RATE TRUST


                             By:        /s/ Christopher J. Kelley
                             Name:     Christopher J. Kelley
                             Title:    Assistant Secretary

CORRESP

                                            Global Markets & Investment Banking

                                            4 World Financial Center - 5th Floor
[GRAPHIC OMITTED][GRAPHIC OMITTED]          New York, New York 10080
MERRILL LYNCH
                                            212-449-6500



                                            December 20, 2004



Mr. Dominic Minore, Esq.
Securities and Exchange Commission
Division of Investment Management
450 Fifth Street, N.W.
Washington, D.C. 20549

Re:      Pioneer Floating Rate Trust (the "Fund")
         Form N-2 Registration Statement No. 333-119731
         Investment Company Act File No. 811-21654

Dear Mr. Minore:

     Pursuant  to Rule  460 of the  General  Rules  and  Regulations  under  the
Securities Act of 1933, as amended (the "Securities  Act"), we, on behalf of the
several  underwriters,  wish to  advise  you that  distribution  of the  amended
Registration Statement,  Form N-2 as filed on November 19, 2004, and Preliminary
Prospectus  dated  November 19,  2004,  were or will be  distributed  during the
period  November 19, 2004 through  December 22, 2004, as follows:  approximately
144,000  copies  of  the   Preliminary   Prospectus  and  a  limited  number  of
Registration  Statements have been or will be sent to underwriters,  dealers and
institutions.

     In accordance with Rule 461 of the General Rules and Regulations  under the
Securities Act of 1933, the  undersigned,  on behalf of the  underwriters of the
offering of common  shares of beneficial  interest of the Fund,  hereby joins in
the  request  of  the  Fund  for  acceleration  of  the  effective  date  of the
above-named  Registration  Statement so that it becomes  effective at 2:00 p.m.,
Eastern Time on December 22, 2004, or as soon as possible thereafter.

                               Very truly yours,

                               MERRILL LYNCH & CO.
                               MERRILL LYNCH, PIERCE, FENNER & SMITH
                               INCORPORATED


                                /s/ Richard A. Diaz
                               --------------------------------------------
                               Name:  Richard A. Diaz
                               Title: Authorized Signatory