CORRESP 2 floataccltr122004.txt REQUEST FOR ACCELERATION 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