EXEMPT ORDER INFO

Annual CCO Certification Pursuant to Form N-
CEN Item G.1.a.v.( )

In regard to the interfund lending program, I certify
that the Lord Abbett Family of Funds and Lord,
Abbett & Co. LLC have established procedures
reasonably designed to achieve compliance with the
terms and conditions of the exemptive order issued
by the U.S. Securities and Exchange Commission,
which are designed to achieve the following
objectives:  (a) that the Interfund Loan Rate will be
higher than the Repo Rate, but lower than the Bank
Loan Rate; (b) compliance with the collateral
requirements as set forth in the Application; (c)
compliance with the percentage limitations on
interfund borrowing and lending; (d) allocation of
interfund borrowing and lending demand in an
equitable manner and in accordance with
procedures established by the Fund Board; and (e)
that the interest rate on any Interfund Loan does not
exceed the interest rate on any third-party
borrowings of a borrowing Fund at the time of the
Interfund Loan.


/s/ Joseph McGill
			January 2, 2019
Joseph McGill
Chief Compliance Officer
The Lord Abbett Family of Funds

(1) Certain capitalized terms used in this
certification have the meanings given to them in the
Lord Abbett Family of Funds' and Lord, Abbett &
Co. LLC's joint exemptive application filed with
the U.S. Securities and Exchange Commission on
June 22, 2016.

INTERNAL CONTROL RPT

REPORT OF INDEPENDENT REGISTERED
PUBLIC ACCOUNTING FIRM

To the shareholders and the Board of Directors
of Lord Abbett Bond-Debenture Fund, Inc.:

In planning and performing our audit of the
financial statements of Lord Abbett Bond-
Debenture Fund, Inc. (the "Fund") as of and for the
year ended December 31, 2018, in accordance with
the standards of the Public Company Accounting
Oversight Board (United States) (PCAOB), we
considered the Fund's 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 Fund's internal control over
financial reporting. Accordingly, we express no
such opinion.

The management of the Fund 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 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 generally accepted accounting principles, and
that receipts and expenditures of the fund are being
made only in accordance with authorizations of
management and directors 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 fund's annual or interim financial statements
will not be prevented or detected on a timely basis.

Our consideration of the Fund's 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 PCAOB. However, we
noted no deficiencies in the Fund's internal control
over financial reporting and its operation, including
controls for safeguarding securities, that we
consider to be a material weakness, as defined
above, as of December 31, 2018.

This report is intended solely for the information
and use of management and the Board of Directors
of the Fund 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/DELOITTE & TOUCHE LLP

New York, New York
February 28, 2019