11 Greenway Plaza
Suite 1000
Houston, Texas 77046-1173
|
||||
July 9, 2020
VIA EDGAR
Ms. Jaea Hahn
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
|
Re:
|
AIM Investment Funds (Invesco Investment Funds)
(CIK No.: 0000826644; 1940 Act No.: 811-05426)
AIM International Mutual Funds (Invesco International Mutual Funds)
(CIK No.: 0000880859; 1940 Act No.: 811-06463)
|
Comment 1:
|
Given that the Preliminary Proxy Statement states that the Meeting will be conducted exclusively online via live webcast, please confirm that the Meeting will adhere
to the “Staff Guidance for Conducting Shareholder Meetings in Light of COVID-19 Concerns,” as updated April 7, 2020, issued by the staff of the Division of Corporation Finance and the Division of Investment Management of the SEC to assist issuers, shareholders, and other market participants affected by coronavirus disease 2019 with meeting their obligations under the federal proxy rules (“Staff Guidance”).
|
Response 1:
|
The Registrants confirm that the Meeting will adhere to the Staff Guidance relating to virtual shareholder meetings.
|
Comment 2:
|
In the section entitled “Questions About the Proposal” under the heading “Why are shareholders being asked to approve these changes?” the disclosure states that “for
the past several years, each Fund has had a high concentration of investments that are greater than 5% of the Fund’s
|
assets in any one issuer.” Please clarify if the Funds have had to reposition investments or make potential adverse investment decisions as a result in order to
remain a diversified fund.
|
|
Response 2:
|
The Preliminary Proxy Statement has been revised as follows:
|
However, for the past several years, each Fund has had a high concentration of investments that are greater than 5% of the Fund’s assets in any one issuer, which, at times, has resulted in the Fund having had to trim positions or limit new investments.
|
|
Comment 3:
|
The Preliminary Proxy Statement states that the purpose of the Meeting is to approve changing each Fund’s sub-classification from “diversified” to “non-diversified”
and approve the elimination of a related fundamental investment restriction. Please confirm that there will be no additional changes to the Funds’ fundamental investment policies other than the elimination of the fundamental investment
restriction as stated. If there are additional changes, please provide a side-by-side comparison of such changes.
|
Response 3:
|
The Registrants confirm that there are no additional changes to the Funds’ fundamental investment policies other than the removal of each Fund’s fundamental investment restriction
relating to the Fund’s diversification classification as detailed in the Preliminary Proxy Statement.
|
Comment 4:
|
Please confirm whether each Fund’s change from a diversified fund to a non-diversified fund will have any indirect impact on its fees. For example, will it impact
the Funds’ portfolio turnover or related expenses that might potentially impact the Funds’ Expense Limitation Agreements?
|
Response 4:
|
The Registrants confirm that they do not believe that the Proposal will have any indirect impact on the expenses of the Funds other than the costs related to the expenses of preparing,
printing and mailing of the proxy solicitation materials and other related costs in connection with the solicitation of proxies for the Proposal. The Registrant notes that some or all of these expenses may be borne by the Adviser under the
Funds’ Expense Limitation Agreements.
|
Comment 5:
|
In the discussion of the Proposal, the Preliminary Proxy Statement specifies that the Boards considered all relevant
factors, including the potential impact of the Proposal on the Funds and their risk profiles. Please discuss any other factors that were considered by the Boards that weighted against the approval of the Proposal.
|
Response 5:
|
The Registrants believe that the Boards’ considerations discussion fairly characterizes the factors that the Boards weighed, and to the best of the Registrants’ knowledge, there were no
factors that weighted against approval other than as disclosed.
|
Sincerely,
|
|
/s/ Taylor V. Edwards
|
|
Taylor V. Edwards
|
cc:
|
Emily Ast, Esq., Invesco Advisers, Inc.
Jacqueline Edwards, Esq., Stradley Ronon Stevens & Young, LLP
John Dikmak, Jr., Esq., Stradley Ronon Stevens & Young, LLP
|