0000276776-14-000034.txt : 20140612
0000276776-14-000034.hdr.sgml : 20140612
20140430170320
ACCESSION NUMBER: 0000276776-14-000034
CONFORMED SUBMISSION TYPE: CORRESP
PUBLIC DOCUMENT COUNT: 2
FILED AS OF DATE: 20140430
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: PIONEER EMERGING MARKETS FUND
CENTRAL INDEX KEY: 0000921023
IRS NUMBER: 043233999
STATE OF INCORPORATION: DE
FISCAL YEAR END: 1130
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: 60 STATE ST
STREET 2: 13TH FLOOR
CITY: BOSTON
STATE: MA
ZIP: 02109-1820
BUSINESS PHONE: 6174224947
MAIL ADDRESS:
STREET 1: 60 STATE ST
STREET 2: 13TH FLOOR
CITY: BOSTON
STATE: MA
ZIP: 02109-1820
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: PIONEER STRATEGIC INCOME FUND
CENTRAL INDEX KEY: 0001077452
IRS NUMBER: 043453709
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: 60 STATE ST
CITY: BOSTON
STATE: MA
ZIP: 02109
BUSINESS PHONE: 6174224960
MAIL ADDRESS:
STREET 1: 60 STATE ST
CITY: BOSTON
STATE: MA
ZIP: 02109
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: PIONEER HIGH YIELD FUND
CENTRAL INDEX KEY: 0001094521
IRS NUMBER: 043500606
STATE OF INCORPORATION: DE
FISCAL YEAR END: 1031
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: 60 STATE STREET 13TH FLOOR
CITY: BOSTON
STATE: MA
ZIP: 02109
BUSINESS PHONE: 6174224947
MAIL ADDRESS:
STREET 1: 60 STATE STREET
STREET 2: 13TH FLOOR
CITY: BOSTON
STATE: MA
ZIP: 02109
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: PIONEER HIGH INCOME TRUST
CENTRAL INDEX KEY: 0001166258
IRS NUMBER: 020563892
STATE OF INCORPORATION: DE
FISCAL YEAR END: 0331
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: 60 STATE ST.
STREET 2: 13TH FL.
CITY: BOSTON
STATE: MA
ZIP: 02109
BUSINESS PHONE: 6174224947
MAIL ADDRESS:
STREET 1: 60 STATE ST
STREET 2: 13TH FL
CITY: BOSTON
STATE: MA
ZIP: 02109
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: PIONEER MUNICIPAL HIGH INCOME TRUST
CENTRAL INDEX KEY: 0001223026
IRS NUMBER: 030512430
STATE OF INCORPORATION: DE
FISCAL YEAR END: 0430
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: 60 STATE STREET
STREET 2: 19TH FLOOR
CITY: BOSTON
STATE: MA
ZIP: 02109
BUSINESS PHONE: 6177427825
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: PIONEER SERIES TRUST I
CENTRAL INDEX KEY: 0001257951
IRS NUMBER: 000000000
STATE OF INCORPORATION: DE
FILING VALUES:
FORM TYPE: CORRESP
MAIL ADDRESS:
STREET 1: 60 STATE ST
CITY: BOSTON
STATE: MA
ZIP: 02109
FORMER COMPANY:
FORMER CONFORMED NAME: PIONEER GROWTH FUND
DATE OF NAME CHANGE: 20030801
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: Pioneer Floating Rate Trust
CENTRAL INDEX KEY: 0001305767
IRS NUMBER: 582683903
FISCAL YEAR END: 1130
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: 60 STATE STREET
CITY: BOSTON
STATE: MA
ZIP: 02109
BUSINESS PHONE: 617-422-4947
MAIL ADDRESS:
STREET 1: 60 STATE STREET
CITY: BOSTON
STATE: MA
ZIP: 02109
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: Pioneer Series Trust VI
CENTRAL INDEX KEY: 0001380192
IRS NUMBER: 000000000
STATE OF INCORPORATION: DE
FISCAL YEAR END: 1031
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: 60 STATE STREET
CITY: BOSTON
STATE: MA
ZIP: 02109
BUSINESS PHONE: 617-742-7825
MAIL ADDRESS:
STREET 1: 60 STATE STREET
CITY: BOSTON
STATE: MA
ZIP: 02109
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: PIONEER MUNICIPAL HIGH INCOME ADVANTAGE TRUST
CENTRAL INDEX KEY: 0001258943
IRS NUMBER: 810634319
STATE OF INCORPORATION: DE
FISCAL YEAR END: 0331
FILING VALUES:
FORM TYPE: CORRESP
MAIL ADDRESS:
STREET 1: 60 STATE STREET
CITY: BOSTON
STATE: MA
ZIP: 02109
FORMER COMPANY:
FORMER CONFORMED NAME: PIONEER MUNICIPAL ADVANTAGE TRUST
DATE OF NAME CHANGE: 20030807
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: PIONEER IBBOTSON ASSET ALLOCATION SERIES
CENTRAL INDEX KEY: 0001288255
IRS NUMBER: 000000000
STATE OF INCORPORATION: DE
FISCAL YEAR END: 0731
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: 60 STATE ST
CITY: BOSTON
STATE: MA
ZIP: 02109
BUSINESS PHONE: 6174224947
MAIL ADDRESS:
STREET 1: 60 STATE ST
CITY: BOSTON
STATE: MA
ZIP: 02109
FORMER COMPANY:
FORMER CONFORMED NAME: PIONEER ASSET ALLOCATION SERIES
DATE OF NAME CHANGE: 20040422
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: Pioneer Series Trust III
CENTRAL INDEX KEY: 0001306349
IRS NUMBER: 000000000
STATE OF INCORPORATION: DE
FISCAL YEAR END: 0630
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: 60 STATE STREET
CITY: BOSTON
STATE: MA
ZIP: 02109
BUSINESS PHONE: (617)742-7825
MAIL ADDRESS:
STREET 1: 60 STATE STREET
CITY: BOSTON
STATE: MA
ZIP: 02109
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: Pioneer Series Trust IV
CENTRAL INDEX KEY: 0001331854
IRS NUMBER: 000000000
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: 60 STATE STREET
CITY: BOSTON
STATE: MA
ZIP: 02109
BUSINESS PHONE: 617-742-7825
MAIL ADDRESS:
STREET 1: 60 STATE STREET
CITY: BOSTON
STATE: MA
ZIP: 02109
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: Pioneer Series Trust V
CENTRAL INDEX KEY: 0001341256
IRS NUMBER: 000000000
STATE OF INCORPORATION: DE
FISCAL YEAR END: 0831
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: 60 STATE STREET
CITY: BOSTON
STATE: MA
ZIP: 02109
BUSINESS PHONE: 617-742-7825
MAIL ADDRESS:
STREET 1: 60 STATE STREET
CITY: BOSTON
STATE: MA
ZIP: 02109
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: Pioneer Diversified High Income Trust
CENTRAL INDEX KEY: 0001388126
IRS NUMBER: 000000000
STATE OF INCORPORATION: DE
FISCAL YEAR END: 0430
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: 60 STATE STREET
CITY: BOSTON
STATE: MA
ZIP: 02109
BUSINESS PHONE: 617-742-7825
MAIL ADDRESS:
STREET 1: 60 STATE STREET
CITY: BOSTON
STATE: MA
ZIP: 02109
FORMER COMPANY:
FORMER CONFORMED NAME: Pioneer Diversified Income Opportunity Trust
DATE OF NAME CHANGE: 20070129
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: PIONEER BOND FUND /DE/
CENTRAL INDEX KEY: 0000276776
IRS NUMBER: 042652279
STATE OF INCORPORATION: DE
FISCAL YEAR END: 0630
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: 60 STATE ST 13TH FL
CITY: BOSTON
STATE: MA
ZIP: 02109
BUSINESS PHONE: 6174224947
MAIL ADDRESS:
STREET 1: 60 STATE ST
STREET 2: 13TH FLOOR
CITY: BOSTON
STATE: MA
ZIP: 02109-1820
FORMER COMPANY:
FORMER CONFORMED NAME: PIONEER BOND FUND /MA/
DATE OF NAME CHANGE: 19920703
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: PIONEER EQUITY INCOME FUND
CENTRAL INDEX KEY: 0000869356
IRS NUMBER: 000000000
STATE OF INCORPORATION: DE
FISCAL YEAR END: 1031
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: 60 STATE STREET
CITY: BOSTON
STATE: MA
ZIP: 02109
BUSINESS PHONE: 6174224947
MAIL ADDRESS:
STREET 1: 60 STATE STREET 13TH FLOOR
CITY: BOSTON
STATE: MA
ZIP: 02109-1820
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: PIONEER RESEARCH FUND
CENTRAL INDEX KEY: 0001094522
IRS NUMBER: 043484468
STATE OF INCORPORATION: DE
FISCAL YEAR END: 1231
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: 60 STATE STREET 19TH FLOOR
CITY: BOSTON
STATE: MA
ZIP: 02109
BUSINESS PHONE: 6174224960
MAIL ADDRESS:
STREET 1: 60 STATE STREET
STREET 2: 19TH FLOOR
CITY: BOSTON
STATE: MA
ZIP: 02109
FORMER COMPANY:
FORMER CONFORMED NAME: PIONEER CORE EQUITY FUND
DATE OF NAME CHANGE: 20020429
FORMER COMPANY:
FORMER CONFORMED NAME: PIONEER TAX MANAGED FUND
DATE OF NAME CHANGE: 19990916
FORMER COMPANY:
FORMER CONFORMED NAME: PIONEER TAX MANAGED EQUITY FUND
DATE OF NAME CHANGE: 19990907
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: PIONEER SERIES TRUST II
CENTRAL INDEX KEY: 0001265389
IRS NUMBER: 000000000
STATE OF INCORPORATION: DE
FISCAL YEAR END: 1231
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: 60 STATE STREET
CITY: BOSTON
STATE: MA
ZIP: 02109
BUSINESS PHONE: 617-422-4947
MAIL ADDRESS:
STREET 1: 60 STATE STREET
CITY: BOSTON
STATE: MA
ZIP: 02109
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: PIONEER SERIES TRUST XI
CENTRAL INDEX KEY: 0000078758
IRS NUMBER: 042458787
STATE OF INCORPORATION: DE
FISCAL YEAR END: 0930
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: 60 STATE ST
STREET 2: 19TH FLOOR
CITY: BOSTON
STATE: MA
ZIP: 02109
BUSINESS PHONE: 6174224960
MAIL ADDRESS:
STREET 1: 60 STATE STREET, 13TH FLOOR
CITY: BOSTON
STATE: MA
ZIP: 02109-1820
FORMER COMPANY:
FORMER CONFORMED NAME: PIONEER VALUE FUND
DATE OF NAME CHANGE: 20010402
FORMER COMPANY:
FORMER CONFORMED NAME: PIONEER II
DATE OF NAME CHANGE: 19920703
FORMER COMPANY:
FORMER CONFORMED NAME: PIONEER II INC
DATE OF NAME CHANGE: 19851112
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: PIONEER MONEY MARKET TRUST
CENTRAL INDEX KEY: 0000812195
IRS NUMBER: 046569772
STATE OF INCORPORATION: DE
FISCAL YEAR END: 1231
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: 60 STATE ST 13TH FLOOR
CITY: BOSTON
STATE: MA
ZIP: 02109-1820
BUSINESS PHONE: 6174224947
MAIL ADDRESS:
STREET 1: 60 STATE ST 13TH FLOOR
CITY: BOSTON
STATE: MA
ZIP: 02109-1820
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: PIONEER SERIES TRUST VII
CENTRAL INDEX KEY: 0001140157
IRS NUMBER: 043567848
STATE OF INCORPORATION: DE
FISCAL YEAR END: 1031
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: 60 STATE STREET 13TH FLOOR
CITY: BOSTON
STATE: MA
ZIP: 02109
BUSINESS PHONE: 6174224947
MAIL ADDRESS:
STREET 1: 60 STATE STREET 13TH FLOOR
CITY: BOSTON
STATE: MA
ZIP: 02109
FORMER COMPANY:
FORMER CONFORMED NAME: PIONEER GLOBAL HIGH YIELD FUND
DATE OF NAME CHANGE: 20010507
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: PIONEER SHORT TERM INCOME FUND
CENTRAL INDEX KEY: 0001286364
IRS NUMBER: 562451408
FISCAL YEAR END: 0831
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: 60 STATE STREET
CITY: BOSTON
STATE: MA
ZIP: 02109
BUSINESS PHONE: 617-517-8909
MAIL ADDRESS:
STREET 1: 60 STATE STREET
CITY: BOSTON
STATE: MA
ZIP: 02109
FORMER COMPANY:
FORMER CONFORMED NAME: PIONEER SHORT TERM BOND FUND
DATE OF NAME CHANGE: 20040407
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: PIONEER FUND /MA/
CENTRAL INDEX KEY: 0000078713
IRS NUMBER: 046013015
STATE OF INCORPORATION: DE
FISCAL YEAR END: 1231
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: 60 STATE ST., 13TH FLOOR
CITY: BOSTON
STATE: MA
ZIP: 02109
BUSINESS PHONE: 61774224947
MAIL ADDRESS:
STREET 1: 60 STATE ST
STREET 2: 13TH FLOOR
CITY: BOSTON
STATE: MA
ZIP: 02109-1820
FORMER COMPANY:
FORMER CONFORMED NAME: PIONEER FUND INC
DATE OF NAME CHANGE: 19920703
FORMER COMPANY:
FORMER CONFORMED NAME: FIDELITY INVESTMENT ASSOCIATES INC
DATE OF NAME CHANGE: 19680607
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: PIONEER SERIES TRUST VIII
CENTRAL INDEX KEY: 0000893660
IRS NUMBER: 043170886
STATE OF INCORPORATION: MA
FISCAL YEAR END: 1130
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: 60 STATE ST- 13TH FL
CITY: BOSTON
STATE: MA
ZIP: 02109-1820
BUSINESS PHONE: 6174224947
MAIL ADDRESS:
STREET 1: 60 STATE STREET
STREET 2: 13TH FLOOR
CITY: BOSTON
STATE: MA
ZIP: 02109
FORMER COMPANY:
FORMER CONFORMED NAME: PIONEER INTERNATIONAL VALUE FUND
DATE OF NAME CHANGE: 20010730
FORMER COMPANY:
FORMER CONFORMED NAME: PIONEER INTERNATIONAL GROWTH FUND
DATE OF NAME CHANGE: 19930328
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: Pioneer Equity Opportunity Fund
CENTRAL INDEX KEY: 0001301444
IRS NUMBER: 000000000
STATE OF INCORPORATION: DE
FISCAL YEAR END: 1130
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: 60 STATE STREET
CITY: BOSTON
STATE: MA
ZIP: 02109
BUSINESS PHONE: 617-422-4947
MAIL ADDRESS:
STREET 1: 60 STATE STREET
CITY: BOSTON
STATE: MA
ZIP: 02109
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: PIONEER REAL ESTATE SHARES
CENTRAL INDEX KEY: 0000908996
IRS NUMBER: 043201341
STATE OF INCORPORATION: DE
FISCAL YEAR END: 1231
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: 60 STATE ST
STREET 2: 20TH FLOOR
CITY: BOSTON
STATE: MA
ZIP: 02109-1820
BUSINESS PHONE: 6174224700
MAIL ADDRESS:
STREET 1: 60 STATE STREET
STREET 2: 20TH FLOOR
CITY: BOSTON
STATE: MA
ZIP: 02109-1820
FORMER COMPANY:
FORMER CONFORMED NAME: PIONEER WINTHROP REAL ESTATE INVESTMENT FUND
DATE OF NAME CHANGE: 19930713
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: PIONEER SERIES TRUST X
CENTRAL INDEX KEY: 0001174520
IRS NUMBER: 030460956
FISCAL YEAR END: 0331
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: 60 STATE STREET
STREET 2: 13TH FLOOR
CITY: BOSTON
STATE: MA
ZIP: 02109
BUSINESS PHONE: 6174224947
MAIL ADDRESS:
STREET 1: 60 STATE STREET
STREET 2: 13TH FLOOR
CITY: BOSTON
STATE: MA
ZIP: 02109
FORMER COMPANY:
FORMER CONFORMED NAME: PIONEER FUNDAMENTAL GROWTH FUND
DATE OF NAME CHANGE: 20051213
FORMER COMPANY:
FORMER CONFORMED NAME: PIONEER LARGE CAP GROWTH FUND
DATE OF NAME CHANGE: 20020530
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: PIONEER MID CAP VALUE FUND
CENTRAL INDEX KEY: 0000863334
IRS NUMBER: 043091159
STATE OF INCORPORATION: DE
FISCAL YEAR END: 1031
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: 60 STATE ST - 13TH FL
CITY: BOSTON
STATE: MA
ZIP: 02109-1820
BUSINESS PHONE: 6177427825
MAIL ADDRESS:
STREET 1: 60 STATE ST
STREET 2: 13TH FLOOR
CITY: BOSTON
STATE: MA
ZIP: 02109-1820
FORMER COMPANY:
FORMER CONFORMED NAME: PIONEER CAPITAL GROWTH FUND /MA/
DATE OF NAME CHANGE: 19980630
FORMER COMPANY:
FORMER CONFORMED NAME: PIONEER GROWTH TRUST
DATE OF NAME CHANGE: 19920703
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: PIONEER SERIES TRUST XII
CENTRAL INDEX KEY: 0001051010
IRS NUMBER: 000000000
STATE OF INCORPORATION: MA
FISCAL YEAR END: 1231
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: C/O THE PIONEER INVESTMENTS
STREET 2: 60 STATE STREET
CITY: BOSTON
STATE: MA
ZIP: 02109-1820
BUSINESS PHONE: 6174224960
MAIL ADDRESS:
STREET 1: C/O THE PIONEER INVESTMENTS
STREET 2: 60 STATE STREET
CITY: BOSTON
STATE: MA
ZIP: 02109-1820
FORMER COMPANY:
FORMER CONFORMED NAME: PIONEER INDEPENDENCE FUND
DATE OF NAME CHANGE: 19971208
CORRESP
1
filename1.txt
ABX
VIA EDGAR
--- -----
April 30, 2014
Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, D.C. 20549
Re: Staff Review of Pioneer Funds' Financial Statements
---------------------------------------------------
Ladies and Gentlemen:
This letter is to respond to comments received by email on March 25, 2014
and by telephone on March 26, 2014 from Mr. Jeffrey W. Long of the Staff of the
Securities and Exchange Commission (the "Commission") in connection with the
Staff's review of financial statements and other filings filed by open-end and
closed-end Pioneer funds (the "Funds").
A. GENERAL COMMENT
1. COMMENT: The Staff asked that the Registrants provide a letter to the
Commission that includes certain "Tandy" acknowledgments with the
Registrants' response to the Staff's comments.
RESPONSE: A Tandy representation letter executed in connection with the
filing of this response is attached hereto as Exhibit A.
---------
B. MANAGEMENT DISCUSSION OF FUND PERFORMANCE
1. COMMENT: The Staff suggested that the Registrants consider disclosing
the returns of the applicable benchmark index in each Fund's
total returns table.
RESPONSE: The Registrants will revise future disclosure to address the
Staff's comments.
C. SCHEDULE OF INVESTMENTS
1. COMMENT: The Staff noted that the table summarizing inputs used in
valuing a Fund's investments shows inputs by category of
investments (e.g., common stocks, preferred stocks, corporate
bonds, etc.). The Staff requested that, if a table shows material
balances for inputs in multiple levels (i.e., Level 1, Level 2
and/or Level 3), the Registrants break out the inputs shown into
the applicable industry components (e.g., energy, materials,
capital goods, etc.), as reported in the Schedule of Investments.
RESPONSE: The Registrants will expand the table in future reports to
include subcategories when multiple levels within a category are
present. Categories that do not have different levels will be
shown in aggregate. The Registrants respectfully submit that this
approach enables the reader to clearly identify how securities are
being leveled and valued.
2. COMMENT: The Staff requested that, for Funds that invest in payment
in kind ("PIK") bonds, the Registrants disclose both the PIK
portion of the interest rate and the cash portion of the interest
rate in the Schedule of Investments.
RESPONSE: The Registrants confirm that, for Funds that invest in payment in
kind ("PIK") bonds, future disclosure will include both the PIK
portion of the interest rate and the cash portion of the interest
rate in the Schedule of Investments.
D. STATEMENT OF ASSETS AND LIABILITIES
1. COMMENT: The Staff noted that the Form N-CSR filed for Pioneer Dynamic
Credit Fund (formerly, Pioneer Absolute Return Credit Fund) for
the fiscal year ended March 31, 2013 shows a payable due to the
custodian of $2,307,630, with a cost of $2,351,255. The Staff
requested that the Registrant explain in the response the nature
of the payable, and why the cost and payable due amounts are
different.
RESPONSE: The Registrant notes that the "Due to Custodian" payable of
$2,307,630 referenced by the Staff was related to a negative
foreign cash balance at the Fund's fiscal year-end. The
Registrant notes that the difference between the payable amount
and the cost basis was attributable to changes to the cost basis
due to currency exchange rates. The Registrant will consider
changing the line item to "Foreign cash overdraft" should a similar
situation occur in the future.
2. COMMENT: The Staff requested that, to the extent that there is a payable
due to a Fund's officers and directors on the Fund's balance sheet,
such payable should be disclosed separately in accordance with
Regulation S-X, Rule 6-04, Item 12.
RESPONSE: The Registrants confirm that future reports will disclose the
"Trustees' fees" payable as a separate line item in the Statement
of Assets and Liabilities.
E. STATEMENT OF OPERATIONS
1. COMMENT: The Staff noted that Form N-CSR filed for Pioneer Dynamic Credit
Fund (formerly, Pioneer Absolute Return Credit Fund) for the
fiscal year ended March 31, 2013 shows a line item for
miscellaneous expenses in an amount that is greater than 5% of
the Fund's total expenses shown. The Staff requested that if
any individual miscellaneous expense is greater than 5% of the
Fund's total expenses, such expense should be broken out as a
separate line item in accordance with Regulation S-X, Rule 6-07,
Item 2.(b).
RESPONSE: The Registrants confirm that in future reports any individual
miscellaneous expense will be broken out as a separate line
item if such miscellaneous expense is greater than 5% of the
Fund's total expenses.
F. STATEMENT OF CHANGES IN NET ASSETS
1. COMMENT: The Staff noted that Form N-CSR filed for Pioneer Emerging
Markets Local Currency Debt Fund for the fiscal year ended October
31, 2013 shows distributions to shareholders representing a tax
return of capital. The Staff requested that the Registrant
confirm that it complied with Section 19(a) of the 1940 Act and
Rule 19a-1 notice requirements with respect to such return of
capital distributions.
2
RESPONSE: The Registrant notes that the tax return of capital referenced
by the Staff did not represent an over distribution of income on a
book/GAAP basis. Rather, the tax return of capital referenced by
the Staff was the direct result of foreign currency losses
reclassified from capital gains to ordinary income as required for
federal income tax purposes under Internal Revenue Code (S)988.
Accordingly, the Registrant respectfully submits that a
Section 19(a) notice was not required with respect to the tax
return of capital referenced by the Staff.
G. FINANCIAL HIGHLIGHTS
1. COMMENT: The Staff noted that Form N-CSR filed for Pioneer Oak Ridge Small
Cap Growth Fund for the fiscal year ended November 30, 2013
indicates that the expense and other ratios were annualized for
the most recent fiscal year. The Staff requested that the
Registrant confirm that this was a typographical error or
otherwise explain why such ratios were annualized.
RESPONSE: The Registrant confirms that Pioneer Oak Ridge Small Cap Growth
Fund's expense ratios were not annualized and that this was a
typographical error. Corrected financial statements will be posted
to Pioneer's website and filed on Form N-CSR/A.
2. COMMENT: The Staff noted that Form N-CSR filed for Pioneer Diversified High
Income Trust for the fiscal year ended April 30, 2013 breaks
out the Fund's operating expenses into "net operating expenses" of
1.49%, "interest expense" of 0.48%, and "net expenses" of 1.97%.
The Staff noted that (i) the Registrant should disclose the Fund's
total expense ratio as 1.97% as required by Form N-2, (ii) to the
extent that Registrant breaks out interest expense or other
components of the Fund's total expense ratio, such interest expense
and any other expenses should be shown in a footnote to the
financial highlights, and (iii) the Registrant should not use the
term "net expenses" if such expenses do not reflect a fee waiver.
RESPONSE: The Registrant confirms that in future reports (i) it will disclose
the Fund's total expense ratio as required by Form N-2, (ii)
interest expense (or other components of the fund's total expense
ratio) will be disclosed in a footnote to the financial highlights
rather than in the body of the statement, and (iii) the term "net
expenses" will only apply to Funds that are subject to expense
waivers/reductions.
H. NOTES TO THE FINANCIAL STATEMENTS
1. COMMENT: The Staff noted that the Notes to the Financial Statements for
certain Funds, including Pioneer Dynamic Credit Fund (formerly,
Pioneer Absolute Return Credit Fund), Pioneer Floating Rate Fund
and Pioneer Strategic Income Fund, indicate that the Fund invested
in credit default swaps.
a. COMMENT: The Staff requested that the Registrants confirm that
each Fund is covering the full notional value of any credit default
swap where the Fund is the seller of protection.
RESPONSE: The Registrants confirm that each Fund covers the full
notional value of any single name credit default swap where the
Fund is the seller of protection.
3
b. COMMENT: The Staff requested that the Registrants make clear in the
Schedule of Investments whether the Fund is the buyer of protection
or the seller of protection on a credit default swap. The Staff
noted that some fund complexes list buy protection and sell
protection credit default swaps separately in the Schedule of
Investments.
RESPONSE: The Registrants confirm that in future reports modified
swap disclosure tables will be incorporated into the Schedule of
Investments that clearly differentiate "Credit Default Swaps - Buy
Protection" from "Credit Default Swaps - Sell Protection."
c. COMMENT: The Staff noted that Form N-CSR filed for Pioneer Dynamic
Credit Fund (formerly, Pioneer Absolute Return Credit Fund) for the
fiscal year ended March 31, 2013 appears to indicate that upfront
payments received by the Fund as the seller of protection were
recorded as liabilities in the Fund's records, while Form N-CSR
filed for Pioneer Floating Rate Fund for the fiscal year ended
October 31, 2013 appears to indicate that such upfront payments were
recorded as assets. The Staff requested that the Registrants
explain in the response why such payments were treated differently.
RESPONSE: The Registrant confirms that the line item description
for Pioneer Dynamic Credit Fund was mislabeled. It should have
stated "swap premiums paid" instead of "swap premiums received."
d. COMMENT: The Staff requested that, to the extent that a Fund buys
or sells protection with respect to a reference index, the Fund
provide a general description in plain English of the reference
index and the constituents of the index, in order to provide
shareholders with an understanding of the instruments with respect
to which the Fund is buying or selling protection. As an example,
the Staff referred to Form N-CSR filed for Pioneer Floating Rate
Trust for the fiscal year ended October 31, 2013, which indicates
in the Schedule of Investments that the Fund sold protection on a
credit default swap listed as "JPMorgan Chase & Co., Markit
CDX.NA.HY.20."
RESPONSE: The Registrant confirms that in future reports swap
disclosures will provide a general description in plain English of
the referenced index in a footnote to the swap tables.
2. COMMENT: The Staff noted that Note 2 in Form N-CSR filed for Pioneer
Diversified High Income Trust for the fiscal year ended April 30,
2013 states that for the year ended April 30, 2013, the net
management fee was 0.85% of the Fund's average daily managed
assets, which was equivalent to 0.60% of the Fund's average daily
net assets. The Staff requested that the Registrant confirm the
Fund's management fee as a percentage of the Fund's average daily
net assets for the fiscal year ended April 30, 2013. The Staff
noted that it generally would expect the fee expressed as a
percentage of the Fund's average daily net assets to be higher
than the fee expressed as a percentage of the Fund's average
daily managed assets.
RESPONSE: The Registrant confirms that for the year ended April 30,
2013, it should have reported a net management fee of 0.85% of the
Fund's average daily managed assets, which was equivalent to 1.20%
of the Fund's average daily net assets. The Registrant notes
that it correctly reported the Fund's management fee as a
percentage of the Fund's average daily net assets in its
semi-annual report for the period ended October 31, 2013.
4
3. COMMENT: The Staff requested that the Registrants disclose any provision of
a Fund's expense limitation arrangement that permits the adviser to
recoup any amounts waived or expenses reimbursed.
RESPONSE: The Registrants confirm that the adviser has no ability to recoup
any amounts waived or expenses reimbursed with respect to a Fund
under the expense limit agreement.
I. FILING HISTORY
1. COMMENT: The Staff requested that the Registrants explain why the following
amended filings were made. In the future, Registrants should
include a cover sheet or explanatory paragraph detailing the
reason for the amended filing. In addition, for amended filings
with certification requirements, the Staff would expect those
certifications to be updated to the amended filing date.
RESPONSE: The Registrants have provided explanations below for the amended
filings. The Registrants confirm that in the future amended
filings will include a paragraph explaining the reason for the
amended filing. The Registrants also confirm that amended filings
with certification requirements will include updated certifications.
ORIGINAL AMENDED
REGISTRANT FILE NO. FORM FILING DATE FILING DATE EXPLANATION
----------------- ----------- -------- ------------ ------------ ------------------------------
Pioneer Floating 811-21654 N-CSR/A 7/30/13 9/13/13 The total returns at net asset
Rate Trust value and at market price
were incorrectly reported in
the Portfolio Management
Discussion, Performance
Update and Financial
Highlights sections. The
information was corrected
and the filing was amended.
Pioneer High 811-21043 N-Q/A 2/26/14 3/4/14 During an internal quality
Income Trust review, it was noticed that
one of the two areas on the
Sarbanes-Oxley certification
where the president's name
appears showed the former
president's name. The
Sarbanes-Oxley certification
was corrected and the filing
was amended.
Pioneer Municipal 811-21409 N-CSR/A 11/29/12 3/6/13 Net investment income
High Income was revised due to certain
Advantage Trust income and expense accounts
not being closed out
correctly at their last fiscal
year end by the sub-administrator.
This error occurred after the
transition to a new
sub-administrator.
5
ORIGINAL AMENDED
REGISTRANT FILE NO. FORM FILING DATE FILING DATE EXPLANATION
----------------- ----------- -------- ------------ ------------ ------------------------------
Pioneer Municipal 811-21409 N-Q/A 2/26/14 3/4/14 During an internal quality
High Income review, it was noticed that
Advantage Trust one of the two areas on
the Sarbanes-Oxley
certification where the
president's name appears
showed the former president's
name. The Sarbanes-Oxley
certification was corrected
and the filing was amended.
Pioneer Municipal 811-21321 N-CSR/A 12/28/12 3/6/13 Net investment income was
High Income Trust revised due to certain income
and expense accounts not
being closed out correctly at
their last fiscal year end by
the sub-administrator. This
error occurred after the
transition to a new
sub-administrator.
Pioneer Series 811-21978 N-CSR/A 12/27/13 1/30/14 Pioneer Multi-Asset Real
Trust VI Return Fund restated its
Class K expense ratios in the
financial highlights.
Originally, the total expense
waiver was allocated to each
share class based on average
net assets instead of on amounts
actually accrued. The $0.42
adjustment to Class K caused
a significant distortion to the
expense ratios due to the
size of the new share class.
J. SERIES AND CLASS INFORMATION
1. COMMENT: The Staff requested that the Registrants update the series and
class information in Edgar to include the ticker symbols for
certain classes of Fund shares.
RESPONSE: The Registrants confirm that they will update the series and class
information in Edgar to include the ticker symbols for certain
classes of Fund shares.
2. COMMENT: The Staff requested that the Registrants update the status for
certain classes of Fund shares marked as "Active" in Edgar, but
appear to be inactive.
RESPONSE: The Registrants confirm that they will update the status for
certain classes of Fund shares from active to inactive, as
appropriate.
3. COMMENT: The Staff noted that several funds have been acquired by other
funds or liquidated. The Staff requested that the Registrants
file Form N-8Fs to deregister the following trusts: Pioneer
Equity Opportunity Fund and Pioneer Research Fund.
RESPONSE: The Registrants confirm that they will file Form N-8Fs to deregister
the following trusts: Pioneer Equity Opportunity Fund and Pioneer
Research Fund.
6
Please contact me directly at 617-422-4468 if you require any further
clarification.
Very truly yours,
/s/ Mark E. Bradley
------------------------
Mark E. Bradley
Treasurer, Pioneer Funds
cc: Michael Melnick
Christopher Frazier
Christopher Kelley
Thomas Reyes
7
COVER
2
filename2.txt
Exhibit A
---------
PIONEER FUNDS
60 State Street
Boston, Massachusetts 02110
April 30, 2014
VIA EDGAR
--- -----
Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, D.C. 20549
Re: Staff Review of Pioneer Funds' Financial Statements
Pioneer Bond Fund (File No. 811-02864)
Pioneer Diversified High Income Trust (File No. 811-22014)
Pioneer Emerging Markets Fund (File No. 811-08448)
Pioneer Equity Income Fund (File No. 811-08657)
Pioneer Equity Opportunity Fund (File No. 811-21623)
Pioneer Floating Rate Trust (File No. 811-21654)
Pioneer Fund (File No. 811-01466)
Pioneer High Income Trust (File No. 811-21043)
Pioneer High Yield Fund (File No. 811-09685)
Pioneer Ibbotson Asset Allocation Series (File No. 811-21569)
Pioneer Mid Cap Value Fund (File No. 811-06106)
Pioneer Money Market Trust (File No. 811-05099)
Pioneer Municipal High Income Advantage Trust (File No. 811-21409)
Pioneer Municipal High Income Trust (File No. 811-21321)
Pioneer Real Estate Shares (File No. 811-07870)
Pioneer Research Fund (File No. 811-09585)
Pioneer Series Trust I (File No. 811-21425)
Pioneer Series Trust II (File No. 811-21460)
Pioneer Series Trust III (File No. 811-21664)
Pioneer Series Trust IV (File No. 811-21781)
Pioneer Series Trust V (File No. 811-21823)
Pioneer Series Trust VI (File No. 811-21978)
Pioneer Series Trust VII (File No. 811-10395)
Pioneer Series Trust VIII (File No. 811-07318)
Pioneer Series Trust X (File No. 811-21108)
Pioneer Series Trust XI (File No. 811-08135)
Pioneer Series Trust XII (File No. 811-08547)
Pioneer Short Term Income Fund (File No. 811-21558)
Pioneer Strategic Income Fund (File No. 811-09223) (The "Registrants")
Ladies and Gentlemen:
In connection with the review by the Staff of the Securities and Exchange
Commission (the "Commission") of financial statements and other filings filed by
open-end and closed-end Pioneer
funds (the "Funds"), the Registrants acknowledge that, with respect to filings
made by the Registrants with the Commission and reviewed by the Staff:
(a) the Registrants are responsible for the adequacy and accuracy of the
disclosure in the filings;
(b) Staff comments or changes to disclosure in response to Staff comments
in the filings reviewed by the Staff do not foreclose the Commission
from taking any action with respect to the filings; and
(c) the Registrants may not assert Staff comments as a defense in any
proceeding initiated by the Commission or any person under the federal
securities laws of the United States.
Sincerely,
/s/ Mark E. Bradley
-----------------------
Mark E. Bradley
Treasurer