[Invesco Letterhead]
11 Greenway Plaza
Suite 1000
Houston, TX 77046
February 20, 2020
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Investment Management
Disclosure Review and Accounting Office
100 F Street NE
Washington, DC 20549
Re: | AIM Sector Funds (Invesco Sector Funds) |
CIK No. 0000725781; File No. 333-236070 |
Ladies and Gentlemen:
In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, AIM Sector Funds (Invesco Sector Funds) (the Registrant) and Invesco Distributors, Inc., the distributor of the Registrants shares, hereby request acceleration of the effective date of Pre-Effective Amendment No. 1 to the Registrants Registration Statement on Form N-14 (File No. 333-236070) so that such Registration Statement may be declared effective on February 24, 2020, or as soon as practicable thereafter.
The Registrant hereby acknowledges that: (1) should the Securities and Exchange Commission (the Commission) or its staff (Staff), acting pursuant to delegated authority, declare the above-referenced registration statement effective, it does not foreclose the Commission from taking any action with respect to the filing; (2) the Registrant is responsible for the adequacy and accuracy of the disclosure in the filing and the Staffs comments, the Registrants changes to the disclosure in response to the Staffs comments or the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, do not relieve the Registrant of this responsibility; and (3) the Registrant may not assert this action or the Staffs comments as a defense in any proceeding initiated by the Commission under the federal securities laws of the United States.
Please contact Kenneth L. Greenberg, Esq. of Stradley Ronon at (215) 564-8149 with respect to this acceleration request or in his absence, contact me at (404) 493-3463.
Very truly yours,
AIM Sector Funds (Invesco Sector Funds) |
/s/ Jeffrey H. Kupor |
Jeffrey H. Kupor, Esq. Senior Vice President Chief Legal Officer Secretary |
Invesco Distributors, Inc. |
/s/ Jeffrey H. Kupor |
Jeffrey H. Kupor, Esq. Senior Vice President and Secretary |
cc: | Jaea Hahn |