April 21, 2021



Keith S. MacLeod, Esq.
Ropes & Gray LLP
Prudential Tower
800 Boylston Street
Boston, MA 02199-3600

               Re:     PIMCO Flexible Emerging Markets Income Fund
                       File Nos. 333-254586 and 811-23648

Dear Mr. MacLeod:

       On March 22, 2021, you filed a registration statement on Form N-2 for
PIMCO Flexible
Emerging Markets Income Fund (the    Fund   ). Our comments are set forth
below. For
convenience, we generally organized our comments using the headings, defined
terms and page
numbers from the registration statement. Where a comment is made with respect
to the
disclosure in one location of the filing, it applies to all similar disclosure
found elsewhere.

PROSPECTUS
Cover Page
1. The Investment Objectives of the Fund are to seek to provide attractive
risk-adjusted returns
   and current income. Please revise the investment objectives to emphasize
seeking current
   income. See Frequently Asked Questions about Rule 35d-1 (Investment Company
Names),
   no. 9. Please also disclose in plain English what the phrase
risk-adjusted returns    means.
2. The last sentence under    Investment Strategy    states that it is expected
that the Fund
   normally will have a short to longer average portfolio duration (i.e.,
within a zero to 12 year
   range), as calculated by the Investment Manager, although it may be shorter
or longer at any
   time or from time to time depending on market conditions and other factors.
Inasmuch as
   this disclosure sets forth a flexible, open-ended duration policy, please
revise this sentence to
   state that the Fund has no targeted average portfolio duration and, if
accurate, that it can
   range widely from zero to 12 years or more.
 Keith S. MacLeod, Esq.
Page 2
April 21, 2021

3. The fourth sentence under    Portfolio Contents    states that    [w]ithin
the limits of the
   foregoing 80% policy   , the Fund may invest in instruments tied
economically to the United
   States or other developed markets and equity securities. Please clarify the
disclosure to
   indicate that these investments will be excluded from the 80% policy.
4. The second paragraph under    Portfolio Contents    describes how PIMCO
identifies countries
   as emerging market countries and provides a non-exhaustive list of examples
of how the
   Fund may consider a country to be an emerging market country. Please
disclose the specific
   criteria PIMCO will use to identify emerging market countries for purposes
of the Fund   s
   policy to invest at least 80% of its assets in instruments that are tied
economically to
   emerging market countries. See Rule 35d-1(a)(3)(ii) under the Investment
Company Act of
   1940 (   1940 Act   ).
5. The third paragraph under    Portfolio Contents    sets forth the criteria
used by PIMCO to
   determine whether an instrument is economically tied to an emerging market
country. Please
   consider removing such disclosure from the Prospectus cover page as it is
very detailed.
6. The first sentence of the sixth paragraph states that the Fund may invest
through Subsidiaries
   in Alt Lending ABS. Please respond to the following comments with respect to
the
   Subsidiaries.
   a. Disclose any of a Subsidiary   s principal investment strategies or
principal risks that
      constitute principal investment strategies or principal risks of the
Fund.
   b. Confirm to us that the financial statements of each wholly-owned
Subsidiary will be
      consolidated with those of the Fund.
   c. Confirm to us that the investment advisory contract between a Subsidiary
and its
      investment adviser will be filed as an exhibit to the registration
statement.
   d. Confirm to us that (a) a Subsidiary   s management fee (including any
performance fee)
      will be included in the    Management Fee    line item of the fee table
and a Subsidiary   s
      expenses will be included in the    Other Expenses    line item of the
fee table; (b) if a
      Subsidiary is not organized in the U.S., the Subsidiary and its board of
directors will
      agree to designate an agent for service of process in the U.S.; and (c) a
Subsidiary and its
      board of directors will agree to inspection by the staff of the
Subsidiary   s books and
      records, which will be maintained in accordance with Section 31 of the
1940 Act.
7. The first sentence under    Leverage    identifies, among other things,
credit default swaps that
   the Fund will use to add leverage to its portfolio. The second sentence
under    Leverage
   states that the Fund may also enter into transactions other than those noted
above that may
   give rise to a form of leverage, including credit default swaps. Please
revise the disclosure to
   identify credit default swaps only once in these two sentences. Also, please
disclose if the
   Fund will sell credit default swaps and the corresponding risks of doing so.
 Keith S. MacLeod, Esq.
Page 3
April 21, 2021

Prospectus Summary     The Offering (pages 1     2)
8. The third to last sentence of this section states that the Fund reserves the
right to reject a
   purchase order for any reason. Please disclose the circumstances in which
the Fund would
   reject a purchase order. We may have additional comments after reviewing
your response.
Prospectus Summary     Portfolio Management Strategies (pages 3     6)
9. The fourth sentence on page 3 states that PIMCO may choose to focus on
particular countries
   or emerging market regions or industries and sectors at any time and from
time to time. If
   the Fund will be focused on particular countries, regions, industries or
sectors at launch,
   please disclose the specific risks of those countries, regions, industries
or sectors in the
   Principal Risks of the Fund section.
10. The paragraph on pages 4 and 5 identifies the debt instruments in which the
Fund may invest.
    Please review this paragraph and limit the disclosure to only the types of
investments in
    which the Fund will principally invest. Please move disclosure of any
non-principal
    investments to a separate section outside of the Prospectus Summary. See
Instruction to Item
    3.2. of Form N-2 (stating that the synopsis should provide a    clear and
concise [emphasis
    added]    description of the key features of the offering and the Fund,
with cross-references to
    relevant disclosure elsewhere in the Prospectus or Statement of Additional
Information). See
    also Item 8.2.b.(1) of Form N-2; Item 8.4. of Form N-2 and Instruction a.
thereto; ADI 2019-
    08     Improving Principal Risks Disclosure (at text preceding footnote 7).
11. The second full paragraph on page 5 sets forth numerous, multi-layered
criteria used by
    PIMCO to determine whether an instrument is economically tied to an
emerging market
    country. Please revise the disclosure in plain English to provide a clear,
objective discussion
    of how the Fund determines that an instrument is economically tied to an
emerging market
    country.
12. Please explain to us how the following are appropriate criteria for
determining whether an
    instrument is tied economically to an emerging market country:
   a. the currency of settlement of a security is a currency of an emerging
market country; and
   b. with respect to derivative instruments, the underlying assets are
currencies of emerging
      market countries (or baskets or indexes of such currencies).
   Please also explain to us how the    country of risk    criteria applied to
an issuer or an issuer   s
   ultimate parent indicate that a security is economically tied to an emerging
market country.
   See Rule 35d-1(a)(3)(i).
13. The fourth sentence on page 6 states that the Fund   s investments in,
origination of and/or
    securitization of loans may also be limited by the Fund   s intention to
qualify as a regulated
    investment company. Please clarify the disclosure to indicate what
limitations the sentence
    refers (e.g., Subchapter M of the Internal Revenue Code).
 Keith S. MacLeod, Esq.
Page 4
April 21, 2021

14. The last sentence of the second full paragraph on page 6 states that the
Fund may engage in
    short sales. Please confirm whether the Fund intends to use short sales
and, if so, please
    include an estimate of dividend and interest expense on short sales in the
fee table.
    Alternatively, please confirm to us that the Fund has no current intention
to engage in short
    sales (i.e., the Fund will not engage in short sales within one year of the
effective date of the
    registration statement).
15. The first sentence of the third full paragraph on page 6 states that the
Fund may invest in
    other investment companies. Please confirm that, if necessary, the expenses
of such
    investments will be reflected in a separate Acquired Fund Fees and Expenses
line item in the
    fee table. See Instruction 10 to Item 3.1 of Form N-2.
Prospectus Summary     Distributor, Custodian and Transfer Agent (page 9)
16. The second sentence of this section will identify the Fund   s primary
custodian. Please also
    identify the custodian of any wholly-owned Subsidiary.
Prospectus Summary     Principal Risks of the Fund (pages 10     39)
17. This section of the Prospectus Summary is approximately 29 pages. The
Principal Risks of
    the Fund section of the Prospectus is approximately 33 pages. Please
summarize the
    disclosure of the Fund   s principal risks in this section of the
Prospectus Summary. See
    Instruction to Item 3.2. of Form N-2
Prospectus Summary     Principal Risks of the Fund     Foreign (non-U.S.)
Investment
Risk (pages 16     17)
18. Disclosure on pages 16 and 17 describes the risks of investments in China
and Russia. If
    investing in China and Russia are principal strategies of the Fund, please
identify such
    investments in the Fund   s Investment Objectives and Strategies section of
the Prospectus
    Summary or explain to us why doing so is not appropriate.
Prospectus Summary     Securitization Risk (pages 25     26)
19. The first sentence of this risk factor states that the Fund may securitize
its assets, including
    loans it has originated, through a Securitized Vehicle, such as a
wholly-owned subsidiary,
    which is established solely for the purpose of holding such assets. In the
Investment
    Objectives and Strategy section, please disclose in greater detail how the
Fund may securitize
    assets, including the types of assets it may securitize, the types of
vehicles the Fund will use
    to do so (including whether or not all such vehicles will be wholly-owned
subsidiaries of the
    Fund), the types of securities the vehicles will issue (e.g., debt,
equity), how the vehicles will
    issue securities (e.g., in private placements), and what recourse debt
holders will have against
    the Fund   s assets. We may have more comments after reviewing your
response.
20. Please explain to us whether the sale of interests by a securitized vehicle
involves the
    issuance of a senior security by the Fund. If so, please explain to us how
this issuance would
 Keith S. MacLeod, Esq.
Page 5
April 21, 2021

   comply with Sections 18(a)(1) and 18(c) of the 1940 Act. We may have more
comments
   after reviewing your response.
21. Please respond to the following comments with respect to any Securitized
Vehicles that are
    wholly-owned subsidiaries of the Fund.
   a. Disclose that each collateral manager to the Securitized Vehicle will
comply with the
      provisions of the 1940 Act relating to investment advisory contracts
(Section 15) as an
      investment adviser to the Fund under Section 2(a)(20) of the 1940 Act.
Please confirm
      that the management agreement between the Securitized Vehicle and the
manager will be
      filed as an exhibit to the registration statement. Please also confirm
that the collateral
      manager will be identified as an investment adviser to the Fund. See Item
9.1.(b) of
      Form N-2.
   b. Please identify the custodian for the Securitized Vehicle.
   c. Disclose any of the Securitized Vehicles    principal strategies or risks
that constitute
      principal strategies or risks of the Fund. The principal strategies and
risks of the Fund
      should reflect aggregate operations of the Fund and the Securitized
Vehicle.
   d. Confirm to us that the management fee (including any performance fees)
paid to any
      collateral manager of the Securitized Vehicle will be included in the
Management Fee
      line item in the fee table and the other expenses of the Securitized
Vehicle will be
      included in the Other Expenses line item in the fee table.
   e. Confirm to us that the Securitized Vehicles will be organized in the
United States.
      Alternatively, confirm to us that the Securitized Vehicle and any board
of directors it has
      will agree to designate an agent for service of process in the United
States and the
      Securitized Vehicle and any board of directors will agree to inspection
by the staff of the
      Securitized Vehicle   s books and records. Confirm to us that these books
and records will
      be maintained in accordance with Section 31 of the 1940 Act and the rules
thereunder.
   f. Confirm to us that the financial statements of the Securitized Vehicles
will be
      consolidated with those of the Fund.
Prospectus Summary     Principal Risks of the Fund     Market Disruptions Risk
(page 37)
22. This risk factor describes risks associated with global market developments
and disruptions,
    including those arising from public health emergencies, and the possible
impact on the Fund.
    Please consider whether the Fund   s disclosures, including risk
disclosures should be revised
    based on how these events may affect the Fund and its investments and
investment process.
    If you believe that no additional disclosure is warranted, please explain
to us why not.
 Keith S. MacLeod, Esq.
Page 6
April 21, 2021

Summary of Fund Expenses (pages 40     41)
23. In footnote 4 to the fee table, please disclose the period for which the
contractual waiver is
    expected to continue, including the expected termination date and briefly
describe who can
    terminate the waiver contract and under what circumstances.
Portfolio Contents and Other Information     Leverage (pages 77     79)
24. The second to last sentence on page 77 states that the Fund may determine
to issue preferred
    shares. Please confirm whether the Fund intends to issue preferred shares
and, if so, please
    (i) include an estimate of the costs of issuing and maintaining preferred
shares in the fee table
    and (ii) disclose the risks to shareholders in the event of a preferred
shares offering.
    Alternatively, please confirm that the Fund has no current intention to
issue preferred shares
    (i.e., the Fund will not issue preferred shares within one year of the
effective date of the
    registration statement).
Sales Charge     Class A-2 and Class A-4 Common Shares (pages 125     129)
25. The first sentence on page 128, under    Sales at Net Asset Value    states
that Class A-2 and A-
    4 Common Shares may be sold at NAV without an initial sales charge to
certain types of
    accounts or account holders including, among others,    purchases made
through . . . certain
    types of group omnibus plans sponsored by employers, professional or
charitable
    organizations   . Please describe this class of purchases with greater
specificity. See Item
    12(a)(2) of Form N-1A and Instruction 1 thereto.
Sales Charge     How EWCs will be Calculated (pages 128     129)
26. This first sentence of this section states that an EWC is imposed on
repurchases of Class A-2
    and Class A-4 Common Shares    on the amount of the repurchase which causes
the current
    value of your account for the particular class of Common Shares of the Fund
to fall below the
    total dollar amount of your purchase payments subject to the EWC.    Please
clarify the
    quoted disclosure in this sentence.
Sales Charge     Reductions and Waivers of Initial Sales Charges and EWCs (page
129)
27. The first sentence of the second paragraph of this section states that EWCs
may be reduced
    or waived for repurchases where the shareholder can demonstrate hardship
and there will be
    minimal cost borne by the Distributor associated with the repurchase.
Please disclose with
    greater specificity the circumstance in which a hardship would be
demonstrated and the
    repurchase will result in minimal cost borne by the Distributor. See Item
12(a)(2) of Form
    N-1A and Instruction 1 thereto.
Shares Purchased or Held Through Financial Intermediaries (page 130)
28. The first sentence of this section states that the availability of sales
charge waivers and
    discounts may depend on the particular financial intermediary or type of
account through
 Keith S. MacLeod, Esq.
Page 7
April 21, 2021

   which you purchase or hold Fund shares. Please disclose sales charge waivers
and discounts
   made available through specific financial intermediaries. See Item 12(a)(2)
of Form N-1A
   and Instruction 1 thereto; IM Guidance Update 2016-06, at text preceding and
following
   footnote 5.
Net Asset Value (pages 135     137)
29. The second sentence of the second paragraph on page 136 states that whole
loans, including
    those originated by the Fund, generally are fair valued. Please confirm
that the Fund will
    update underlying valuation data with respect to each individual loan that
it holds at least as
    often as it calculates its NAV. Also, please disclose that originated loans
will be valued on
    an individual loan level, fair valuation will be performed using inputs
that incorporate
    borrower level data which is updated as often as the Fund   s NAV is
calculated and the type
    of information that will be used to value loans.
Distributions (pages 137     138)
30. The second sentence of the second paragraph on page 138 states that there
is a possibility that
    the Fund may make total distributions during a taxable year that exceeds
the Fund   s net
    investment income and net realized capital gains (i.e., a return of
capital). Please tell us if the
    Fund may make a significant amount of return of capital distributions in
its first year of
    operations. If so, please prominently disclose on the Prospectus cover page
that the Fund
    expects to make return of capital distributions and that such distributions
do not represent
    income.
Anti-Takeover and Other Provisions in the Declaration of Trust (pages 140
141)
31. Please describe the limitations on the ability of shareholders to bring
direct and derivative
    claims set forth in Sections 5 and 6 of the Fund   s Declaration of Trust.
Please also disclose
    that these limitations do not apply to claims made under the federal
securities laws. In
    addition, please disclose that the forum for adjudication of disputes is
the federal or state
    courts of Massachusetts, as described in Section 11.1 of the Fund   s
Bylaws, and the
    corresponding risks of such provision (e.g., that shareholders may have to
bring suit in an
    inconvenient and unfavorable forum).
STATEMENT OF ADDITIONAL INFORMATION
Investment Restrictions     Other Information Regarding Investment Restrictions
(pages
102     105)
32. Please confirm that the Fund will look through a private activity municipal
debt security
    whose principal and interest payments are derived principally from the
assets and revenues of
    a nongovernmental entity in order to determine the industry to which the
investment should
    be allocated when determining the Fund   s compliance with its
concentration policy.
 Keith S. MacLeod, Esq.
Page 8
April 21, 2021

PART C     OTHER INFORMATION
Item 34. Undertakings
33. Please insert the undertaking set forth in Item 34.4 of Form N-2 or explain
to us why it is not
    applicable.
GENERAL COMMENTS
34. Please tell us if you have presented any test the waters materials to
potential investors in
    connection with this offering. If so, please provide us with copies of such
materials.
35. We note that many portions of your filing are incomplete or to be updated
by amendment
    (e.g., fee table, information regarding Trustees). We may have additional
comments on such
    portions when you complete them in pre-effective amendments, on disclosures
made in
    response to this letter, on information supplied supplementally, or on
exhibits added in any
    pre-effective amendment.
36. If you intend to omit certain information from the form of prospectus
included with the
    registration statement that is declared effective in reliance on Rule 430A
under the Securities
    Act of 1933 (   Securities Act   ), please identify the omitted information
to us supplementally,
    preferably before filing the pre-effective amendment.
37. Please advise us if you have submitted or expect to submit any exemptive
applications or no-
    action requests in connection with your registration statement.
38. Response to this letter should be in the form of a pre-effective amendment
filed pursuant to
    Rule 472 under the Securities Act. Where no change will be made in the
filing in response to
    a comment, please indicate this fact in a supplemental letter and briefly
state the basis for
    your position.
       In closing, we remind you that the Fund and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
                                        * * * * *
       If you have any questions prior to filing a pre-effective amendment,
please call me at
(202) 551-6782.

                                                              Sincerely,

                                                              /s/ Anu Dubey

                                                              Anu Dubey
                                                              Senior Counsel
cc:    Michael Spratt
       Michael Shaffer